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ASCP recently submitted formal comments on the Centers for Medicare and Medicaid Services (CMS) CY 2025 Medicare Physician Fee Schedule (PFS) (NPRM). In it, ASCP raised concerns about the sustainability of CMS’s proposals to ensure patient access to quality pathology services. ASCP noted that this year’s rule marks the fifth straight year of the agency proposing to cut payment rates overall. ASCP raised concern that physician payment rates have fallen significantly since 2001—approximately 26%—because the PFS lacks an inflationary adjustment.

As a result, ASCP urged CMS to work with Congress to address Medicare sustainability. ASCP outlined several bills Congress should enact to address the Medicare payment issues, such as the Strengthening Medicare for Patients and Providers Act (H.R. 2474,) to provide an annual inflationary adjustment for physician service; and the Saving Access to Laboratory Services Act (S. 1000/H.R.1835), to reform how the federal government sets laboratory fees.

ASCP’s comments also addressed CMS’s recent updates to its clinical labor costs. CMS recently updated the PFS direct expenses for technical services performed by non-physician laboratory personnel—including histotechnologists and cytologists. In doing so, CMS adopted data from , a policy change that significantly reduced cuts CMS had proposed for pathology and independent laboratories.

ASCP’s comments also address the inability of the Medicare Quality Payment Program and the Merit-based Incentive Payment System to adequately recognize the critical contributions of pathologists. 

ASCP will continue working with AMA and other medical specialty societies to advocate for appropriate payment reform from Congress.

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