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CAP Update Gene N. Herbek MD, FCAP CAP President April 5, 2014

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Page 1: Cover Title: Century Gothic Bold, 30 Pt, Initial ... · Influenced the favorable GAO report on self-referral and ... • Working with the ACMG, ASCLS, ASCP, ASHI, ... Recommendations

CAP Update Gene N. Herbek MD, FCAP CAP President

April 5, 2014

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Methodist Hospital

Omaha, Nebraska

2 © 2014 College of American Pathologists. All rights reserved.

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Laboratory at Methodist Hospital

Omaha, Nebraska

3 © 2014 College of American Pathologists. All rights reserved.

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• Present an overview and update on the CAP’s

2014 policy and advocacy priorities

• Provide context for the policy challenges we face

• Describe resources and tools available at the CAP

to help you today and tomorrow

• Answer your questions

Today’s Objectives

4 © 2014 College of American Pathologists. All rights reserved.

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• CAP policy and advocacy agenda

• 2013 accomplishments

• Health policy landscape for pathology

• 2014 priorities and challenges

• Mobilizing to advance and sustain the specialty

CAP Advocacy

5 © 2014 College of American Pathologists. All rights reserved.

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CAP Policy and Advocacy Agenda

Mitigate cuts to pathology payments

Ensure pathologists can comply with the new CMS

value based payment models

Ensure a level playing field against unfair

competition

Protect pathologists’ scope of practice

Protect funding for graduate medical education

Sustain a favorable lab regulatory environment

6 © 2014 College of American Pathologists. All rights reserved.

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Blocked CMS plan to cut the TC payments for 39 pathology codes to the level of the Hospital APC rate

Secured relief from penalties and eased compliance with the Physician Quality Reporting System (PQRS) program

Persuaded HHS to shield laboratories from unfair competition by removing labs as potential donors of EHR services

Influenced the favorable GAO report on self-referral and paved the way for potential congressional action

Paved the way for pathologists to avoid CMS Value- Based payment penalties under the new SGR reform bill

What We Accomplished In 2013

7 © 2014 College of American Pathologists. All rights reserved.

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• The Office of Inspector General (OIG) and CMS released

their final rulings on Dec. 23, 2013

• Federal rules banning donations were effective as of

March 27, 2014

• CAP members have reported numerous cases of unfair

and abusive business practices that escalated and ran

contrary to the intent of the safe harbor and the

exception

• In 2011, CAP and PAP secured a state ruling on

laboratory EHR donations in PA that was more restrictive

than federal law in effect prior to December 2013

CAP Advocacy Eliminates Ability of Laboratories to Donate EHR

8 © 2014 College of American Pathologists. All rights reserved.

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Patient Access Rule: Feb. 3, 2014

Visit cap.org/advocacy for more information.

9 © 2014 College of American Pathologists. All rights reserved.

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• HHS continues to implement Affordable Care Act

• CMS initiatives to revalue existing pathology payments at the individual code level will continue

• CMS also seeking authority to rebase payments at the code level on sources other than the RUC

• CMS plan to revalue the Clinical Lab Fee Schedule will also lead to reductions in payments to labs

• Congress acting to repeal the SGR and replace it with a system that revamps existing CMS Value Based Program

Health Policy Landscape for Pathology

10 © 2014 College of American Pathologists. All rights reserved.

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• SGR Reform: CAP is pushing to enact the pending SGR reform bill. It has pathology specific language to help us going forward.

• Self-Referral: CAP is pushing to attach the self-referral ban to the SGR bill. Now is the time to act.

• Immunohistochemistry: 88342 (PC & TC): CAP working to reverse CMS decision to require the use of two new G codes for this service, but the solution may not be finalized until 2015.

• In situ hybridization services: 88365, 88367, and 88368 (PC & TC): CMS deferred final action on the revaluation of these services for 2014, but changes are anticipated beginning in 2015.

2014 Priorities and Challenges

11 © 2014 College of American Pathologists. All rights reserved.

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• 88305 TC and global payment

o The CAP defended from further cuts beyond

those already announced in 2013

• New restrictions on prostate biopsies

• Microdissections

• In Vivo Microscopy (88375)

• Optical Endomicroscopy

2014 PFS: Other Changes to AP Pathology Codes

12 © 2014 College of American Pathologists. All rights reserved.

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• Linking Pathology TC Payments to the Hospital

Outpatient APC Rates: While we succeeded in

2013, CMS remains committed to the policy which

we will continue to oppose in 2014.

• Bundling of Pathology Services: The CAP will be

opposing efforts to bundle pathologist professional

services into bundled payments for hospitals.

• PQRS: CAP is working to ensure that pathologists

can comply with CMS’s PQRS program and will

develop additional measures going forward.

2014 Priorities and Challenges

13 © 2014 College of American Pathologists. All rights reserved.

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• Molecular Payment and Coverage: The CAP

advocating for payment and coverage in face of

restrictive CMS and private payer policies.

• Next Generation Sequencing: The CAP continues to

work with AMP to advance CPT code proposal for

NGS technical component. NGS codes and

Medicare pricing for the technical service is

expected in 2015 and Pathologists can use existing

codes (80502) to bill for NGS consultation services.

2014 Priorities and Challenges

14 © 2014 College of American Pathologists. All rights reserved.

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• Working with the ACMG, ASCLS, ASCP, ASHI, and AMP―representing more than 150,000 medical laboratory professionals―in advocating at the federal level with CMS

• Provided CMS with a 100-page comment letter and met with CMS officials on local coverage decisions

• CAP medical experts are engaging with Medicare contractors

• Partnering with Personalized Medicine Coalitions and the Cancer Leadership Council

CAP’s Advocacy Efforts on Molecular Pathology

15 © 2014 College of American Pathologists. All rights reserved.

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Medicare coverage (or lack thereof) is a major focus of

the CAP’s advocacy efforts:

• Concerned about patient access to medically

necessary molecular pathology testing

• Working on multiple fronts to address concerns with

CMS, patient advocates, and AMA

• Providing more info on tests to national health plans,

including Wellpoint and Cigna, per their request

• Working to prevent adoption of Medicare policy by

private plans

2014: Coverage of Molecular Pathology Services

16 © 2014 College of American Pathologists. All rights reserved.

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• The CAP continues to work with AMP and AMA

workgroups to advance CPT code proposal for NGS

technical component

• Pathologists can use existing codes (80502) to bill

for NGS consultation services

• NGS codes and Medicare pricing expected in 2015

2014: Ensuring Payment for Next-Generation Sequencing (NGS)

17 © 2014 College of American Pathologists. All rights reserved.

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The CAP has made significant progress to address the workforce challenges:

• Advocate on behalf of several bills to lift a GME funding cap.

• Established the CAP Policy Roundtable

o Focused on how to train future pathology workforce

o Published a white paper in Archives on pathology workforce supply (December 2013)

• Held Pathology Workforce Summit in December 2013

o Agreed to set priorities and recommended activities

GME Funding and Policy Roundtable

18 © 2014 College of American Pathologists. All rights reserved.

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• Enacted in March, anatomic pathology anti-

markup legislation in Virginia.

• Hearings to be held for anti-markup and ACO

legislation in Illinois.

• CAP model ACO legislation pending in California

and New Jersey:

o CAP model ACO bill endorsed by four national

cancer patient advocacy groups.

CAP- State Affairs

19 © 2014 College of American Pathologists. All rights reserved.

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• PA SB1042 introduced by Dept. of Health in 2013

• PAP and CAP involved in negotiations from

introduction, including amendments to enhance

clarity of the bill:

o Related to fee-splitting, kickbacks, applicability

to out-of-state laboratories and recognition of

accreditation

o However, not all requested changes received

traction with the Department or Legislature

• Signed into law Dec. 18, 2013 with CAP and PAP

support

State Affairs - Senate Bill 1042

20 © 2014 College of American Pathologists. All rights reserved.

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• Official clarification requested on:

o Mark-up of anatomic pathology services

o Soliciting, collecting, processing, handling and

receiving of specimens by non-permitted

histological processing facilities

o Placement of paid or unpaid personnel,

including pathologists in referring physician

offices

PAP-CAP Letter to Health Department

21 © 2014 College of American Pathologists. All rights reserved.

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Spread the Word….

• Become a CAP member

• Join PathNET, CAP’s grassroots network

• Contribute to PathPAC

• At the State level, join your state pathology society

Together Our Voices Are Key to Our Success

Mobilizing to Sustain the Specialty

22 © 2014 College of American Pathologists. All rights reserved.

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Attend the 2014 CAP Policy Meeting

23 © 2014 College of American Pathologists. All rights reserved.

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Stay Informed….

o Follow CAP on social media

− Twitter @pathologists

− Facebook.com/capathologists

o Visit cap.org/advocacy

o Sign up to receive Statline

24 © 2014 College of American Pathologists. All rights reserved.

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Change Drivers

• Demographics

• Economics

• Emerging technologies

• Care models • Payment systems

© 2014 College of American Pathologists. All rights reserved.

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• Learning

• Practice Management Tools

• CAP Guidelines

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CAP can help you today and tomorrow

© 2014 College of American Pathologists. All rights reserved.

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• Combination of online learning

and live, faculty-led workshops

o Hands-on training

o Networking opportunities

• Earn up to 30 CME and 18 SAM credits

• CAP’s AP3 Certificate of Recognition

o Successful completion of cognitive and practical

assessments

© 2014 College of American Pathologists. All rights reserved. 28

Advanced Practical Pathology Programs (AP3s)

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• CAP offers over 80 SAMs in 25 different specialty

areas

o Peer reviewed

o Highly interactive

o Easily accessible

o Most offer discounts to residents

© 2014 College of American Pathologists. All rights reserved. 29

Online Learning: CAP SAMs

“The CAP seems to be taking a leadership role in developing SAMs with very easy online resources.”

- What SAM participants are saying

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• Education in genomics

o Basic and intermediate learning plans

o Pharmacogenomics Series

o Webinars, SPECs, and Resource Guides

• Education in informatics

o Health Information Technology Primer course

• Education in practice management

o Create and promote your value

© 2014 College of American Pathologists. All rights reserved. 30

CAP can help you prepare for the future

Free course for Residents

Free course for Residents

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Value-Based Business Center

Available to CAP members and Practice Managers Forum

participants

cap.org/practicemanagement

Gather Data

Market Awareness Toolkit

Practice Self-Awareness Toolkit

Market Assessment Toolkit

Practice Assessment Toolkit

Make Decisions Pursue Opportunities

Got Value? Document

Value Impact Analysis Toolkit

Negotiation Skills Online Courses

31 © 2014 College of American Pathologists. All rights reserved.

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CAP Guidelines

Along with professional

partners, the CAP advances

the practice of pathology and

laboratory medicine by

bringing evidence-based

medicine and consensus

recommendations to the

forefront of clinical

decision making.

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CAP Guidelines

The CAP Guidelines help

pathologists and other

clinicians make more informed

decisions about diagnosis and

optimal treatment leading to

more effective testing and

better patient outcomes

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• Immunohistochemistry Assay Analytic Validation Principles

• Guideline Recommendations for HER2 Testing in Breast Cancer

• Validating Whole Slide Imaging for Diagnostic Purposes in Pathology

• Molecular Testing Guideline for Selection of Lung Cancer Patients for

EGFR and ALK Tyrosine Kinase Inhibitor

• The Lower Anogenital Squamous Terminology Standardization Project

for HPV-Associated Lesions: Background and Consensus

Recommendations

• Consensus Statement on Effective Communication of Urgent

Diagnoses and Significant Unexpected Diagnoses in Surgical

Pathology and Cytopathology

• Guideline Recommendations for Immunohistochemical Testing

of Estrogen and Progesterone Receptors in Breast Cancer

CAP Guidelines - Published

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• CAP/ASH Algorithm for Initial Work-up of Acute Leukemia

• CAP-ADASP Interpretive Diagnostic Error Reduction in Surgical

Pathology

and Cytopathology

• Bone Marrow Synoptic Reporting

• CAP-NSH Uniform Labeling Requirements for Blocks and Slides

in Surgical Pathology

ASCP/CAP/AMP/ASCO Molecular Markers for the Evaluation of

Colorectal Cancer

• HER2 Testing in Gastric Cancer

• HPV Testing in Head and Neck Squamous Cell Carcinoma

CAP Guidelines – In Development

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Make Plans to Attend CAP’14

cap.org/cap14

36 © 2014 College of American Pathologists. All rights reserved.

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