With the final 2023 Medicare Physician Fee Schedule (PFS), the Centers for Medicare & Medicaid Services (CMS) finalized the proper rank order of the clinical labor rates for histotechnologists and laboratory technicians, according to the College of American Pathologists (CAP).
As the CAP explains, prior to 2022, clinical labor rates had not been updated in 20 years, which “created a significant disparity between the CMS’ clinical wage data and the market average for clinical labor,” the CAP writes in its Advocacy Update newsletter. CMS used wage data from the Bureau of Labor Statistics (BLS) to update clinical labor pricing in 2022, but for labor categories without available data, CMS extrapolated the wages using supplementary data sources, as in the case of the 2022 clinical labor price per minute for histotechnologists.
With the 2023 PFS, using input from the CAP on current wage data and BLS comparison rates, CMS finalized implementation of the clinical labor update, including corrections over four years to transition to the final updated prices in 2025. Furthermore, the clinical labor pricing updates in 2023 will take place in the second year of the transition. This price will positively impact the technical and global physician service components, according to the CAP.
The final pathology CMS clinical labor rate phase in increases are:
- Laboratory technicians: 67 percent
- Histotechnologists: 73 percent
- Lab tech/histotechnologists blend: 70 percent
The fee schedule payment formula used a final 2023 conversion factor of $33.0607, which is a 4.5 percent decrease from the 2022 conversion factor. This decrease accounts for the update to the 2023 conversion factor of 0 percent; expiration of the 2022 increase to PFS payments by 3 percent; and the budget neutrality adjustment accounting for increases in physician payments.
According to the CAP calculations, the total average Medicare spending impact on pathology will be a decrease of 3.6 percent and a decrease of 3.0 percent for independent laboratories. The CAP says it will continue to advocate for the protection of pathologists’ scope of practice and is working with a coalition of specialty societies and the American Medical Association to ensure that physicians receive accurate reimbursement.
The CAP has prepared an impact table comparing 2022 and 2023 relative value units.