The Association for Molecular Pathology (AMP) submitted comments to the Centers for Medicare and Medicaid Services (CMS) expressing serious concerns about the gap fill process. “Overall, the process neglects to take into account the unique and valuable expertise of the professionals who interpret the data,” said AMP President, Jennifer L. Hunt, MD, MEd, “Acknowledgement of the time, resources, and risk assumed by the specially trained individuals who analyze the complex datasets is absent from the current structure. It is those physicians and doctoral scientists who are legally responsible for the accuracy of the results.”
AMP’s comments point out that since the new codes took effect on January 1, 2013, many laboratories have gone without reimbursement for their services. This lack of coverage is a result of payment amounts that have not yet been determined as well as those in which the cost exceeds the reimbursement amount. “The current payment standard is unsustainable,” said Jan A. Nowak, MD, PhD, Co-Chair of the AMP Economic Affairs Committee (EAC). “Labs are being forced to either discontinue critical tests or endure significant revenue shortages due to lack of coverage under the existing policies.” With laboratories unable to perform certain tests, it is ultimately the patient who suffers.
The absence of transparency within the gap fill process is another significant issue raised by AMP in their comments. Alternative solutions exist that are supported by AMP and other professional societies. These solutions offer the transparency, data collection procedures, payment structures, and the flexibility to adapt as needed based on public input. One solution would have been placement of the new molecular pathology CPT codes on the Physician Fee Schedule (PFS). “Significant effort was spent in determining the practice expense and professional work involved for most of the codes,” said Aaron D. Bossler, MD, PhD, Co-Chair of the AMP EAC. “This data was vetted and accepted by the AMA Specialty Society RVS Update Committee for PFS placement and CMS has this data. We requested that CMS give it full consideration in setting the final gap fill prices.”
As the sole organization dedicated exclusively to the practice and application of molecular pathology, AMP will continue to provide guidance on this and other issues affecting the field. The AMP EAC thanks all the laboratories which provided their cost data for our evaluation and response to CMS. Download AMP’s comments here (PDF).
The Association for Molecular Pathology (AMP) was founded in 1995 to provide structure and leadership to what was, at the time, the newly-emerging field of molecular diagnostics. Through the efforts of its Board of Directors, Committees, Working Groups, and members, AMP has established itself as the primary resource for expertise, education, and collaboration on what is now one of the fastest growing fields in science. AMP members influence policy and regulation on the national and international levels; ultimately serving to advance innovation in the field and protect patient access to high quality, appropriate testing.
AMP’s 2,000+ members include individuals from academic and community medical centers, government, and industry; including, basic and translational scientists, pathologist and doctoral scientist laboratory directors, medical technologists, and trainees. AMP members span the globe with members in more than 45 countries and a growing number of AMP International Affiliate Organizations. The number of AMP members is growing rapidly; they are united by the goal of advancing the science and implementation of molecular pathology. For more information, please visit http://www.amp.org.