[Histonet] FW: ASCP Action Alert: High Priority Action Alert!! MUE Proposal Could Undermine Quality Care, Devastate Clinical Laboratories

From:"Weems, Joyce"

I hesitated before I send this, but we in the US are facing a pathology crisis if we don't do something. For those not in the US I apologize, the rest of us need to do what we can to help! 
Thanks, j
Joyce Weems
Pathology Manager
Saint Joseph’s Hospital of Atlanta
404-851-7831 - fax
High Priority Action Alert!! MUE Proposal Could 
Undermine Quality Care, Devastate Clinical Laboratories!

America’s clinical laboratories are under assault by a federal initiative and ASCP needs your help to defeat it!
The Centers for Medicare and Medicaid (CMS) recently proposed a massive CPT coding edit, placing stringent caps on the units of service that can be provided patients for pathology and laboratory services as well as other medical services.  The initiative could have profound consequences for patient care and could also undermine the financial viability of numerous clinical laboratories.  One clinical laboratory estimates that the proposal could reduce its Medicare Part A reimbursement by 35 percent and its Part B reimbursement by 10 percent.  This proposal might be one of the most harmful policy initiatives faced by clinical laboratories in years.
What’s the Proposal?
CMS’s MUE (Medically Unbelievable Edits) proposal sets limits on the number of units of services that can be billed per patient per day.  The MUE proposal sets limits on almost 1200 pathology and laboratory CPT Codes.  According to CMS, the coding edits proposed prevent billing for items that are either (1) anatomically impossible (can’t remove more than one appendix) or (2) medically unreasonable (more than one pacemaker).  Unfortunately, many of the coding edits proposed by CMS are inconsistent with existing guidelines for diagnosing and treating patients.  Under the proposal CPT code 88305 may not be reimbursed at more than two units of service per patient per day while 88342 would be capped at 4.  MUEs being proposed would allow contractors to “automatically deny the services without stopping the claim for routine or complex review, even if documentation is attached.”  
What is ASCP Doing?
ASCP has written CMS Administrator Mark McClellan to protest the MUE proposal, stating that the coding edits are flawed and threaten quality patient care.  In addition, ASCP is launching a multi-pronged effort to fight this initiative.  This initiative will reach out to ASCP members to seek their technical input on these flaws and to generate grassroots opposition to the CMS proposal.  ASCP plans to compile this information to provide further evidence that CMS’ MUE proposal is fundamentally flawed.
What Can I Do to Help?
To bolster the case that the MUE proposal is flawed, ASCP needs its members’ technical input to help identify clinical scenarios where the MUE proposal is inconsistent with the proper practice of laboratory medicine.  Journal articles or practice guidelines recommending a greater unit of service than that allowed under the MUE proposal would be particularly helpful.  
ASCP urges its members and others in the laboratory community to access ASCP’s e-Advocacy Center to review a condensed version of the MUE proposal.  This condensed list focuses on the top 100 pathology and laboratory codes by reimbursement.  While it does not cover all 1200 CPT codes, the e-Advocacy Center includes instructions for obtaining a copy of the entire MUE proposal.  Also on the e-Advocacy Center is a template for providing technical input to ASCP.  A copy of ASCP’s letter to CMS Administrator Mark McClellan is also on the e-Advocacy Center.
The following are two examples of the type of input that helps bolster the case that the MUE proposal is flawed.
For CPT code 88305 (Level IV – surgical pathology, gross and microscopic examination), the MUE proposal limits reimbursement to only 2 procedures per site per day.  Guidelines developed by the American Gastroenterology Association (AGA) and American Cancer Society (ACS) recommend that for patients with ulcerative colitis, “two to four random biopsy specimens should be obtained every 10 cm from the entire colon for a total of approximately 40 biopsies per patient per colonoscopy, and additional samples should be obtained at any suspicious area.” (7th Symposium on Inflammatory Bowel Diseases and Salicylates).  
For CPT code 88342 (immunocytochemistry (w/tissue immunoperoxidase), each antibody), the MUE proposed limit is 4 units of service per patient per day.  Some tumors cannot be ascertained on histologic grounds, however, and require the aid of immunohistochemical stains.  In the case of anaplastic tumors, a panel of seven immunohistochemical stains is needed (Gatter and Mason, Seminars in Oncology, Vol. 9, No. 4, 1982).  Moreover, in an article by Raab (Arch Pathol Lab Med, Vol. 124, Aug. 2000), the author concluded that “immunohistochemistry is extremely cost-effective,” with a more favorable cost-benefit ratio than other medical procedures.
To provide input on the CMS MUE proposal, please use e-Advocacy Center   to request the necessary documents from the ASCP Washington Office.  We’ll send you a copy of ASCP’s letter to CMS along with a copy of the MUE proposal affecting the top 100 pathology and laboratory service codes (by reimbursement).  If you’d like a copy of the MUE proposal affecting every pathology and laboratory code, please indicate that you would like the expanded document as well.
ASCP thanks you for your efforts to help us better serve you and the laboratory community!
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