CEO SUMMARY: New digital pathology CPT codes took effect Jan. 1. Because the new codes are designated as Category III, they are not subject to Medicare and private payer reimbursement yet. Instead, federal health officials will monitor the use of the new codes in 2023 to determine how often they are used in diagnosis and treatment.
IT’S AN IMPORTANT FIRST FOR DIGITAL PATHOLOGY. As of Jan. 1, new Current Procedural Terminology (CPT) codes of the American Medical Association that recognize the process of converting a glass slide to a digital whole slide image went into effect.
These 13 new CPT entries for digital pathology are Category III codes, meaning they are temporary procedural terminology codes that do not receive reimbursement. Category III designates emerging services and technologies.
The Centers for Medicare and Medicaid Services (CMS) now enters a “tryout” period for at least a part of 2023 to gather data about the use of the new CPT codes in clinical lab and anatomic pathology groups.
“All pathologists should participate in this data collection now in order for the CPT codes to become reimbursable in the future,” recommended Giovanni Lujan, MD, Director of Digital and Computational Pathology at the Ohio State University Wexner Medical Center in Columbus, Ohio.
“The new CPT codes are associated with the different activities that pathologists perform, like examination of a biopsy, a resection specimen, or immunohistochemical stains. So, in all those cases, if we digitize the image to make the diagnosis, we need to add this extra CPT code as a tag to the claim,” explained Lujan, who is also Co-Chair of the Reimbursement/ Market Access Task Force for the Digital Pathology Association.
This development is less about gaining immediate reimbursement for the digital pathology activities and more about accumulating workflow data on electronic specimen handling and diagnostics, Lujan noted.
CMS will monitor the activity of these new codes to see how they are involved with supporting patient care and shortening the time to diagnosis. From there, federal health officials and private payers will assess future reimbursement levels for the steps accounted for in the new CPT codes.
There is not a future guarantee that the new CPT codes will receive reimbursement. In many ways, that decision rests on the efforts of clinical laboratories and pathology practices to use the temporary codes in 2023, said Diana Richard, Senior Director of Pathology and Strategic Development at revenue cycle management firm XIFIN in San Diego.
“If pathologists follow the protocol of adding the new codes to Medicare claims and CMS receives a substantive amount of data from these submissions, I imagine in 2023 we’ll see that conversation evolve into new reimbursable codes for digital pathology, potentially as early as 2024,” Richard explained.
“However, if CMS does not collect a substantive dataset, it could mean conversations around digital pathology reimbursements stall for the next couple of years—or at least until additional incentives or cost savings are put into place to help motivate adoption,” she added.
That initial process of data gathering could take six to 12 months to complete, Lujan said. “CMS will review the results of the digital pathology CPT code usage, and they will determine whether the new codes will be permanent,” he noted. “If they are permanent, CMS will determine the reimbursement value and move them to Category I CPT codes.”
Richard is not aware of any private payers that have independently established rates for the Category III codes or initiated their own feedback process. “The commercial payers are watching and waiting, but I believe their adoption will closely mirror whatever CMS decides to do with digital pathology,” she said.
Digital Pathology Decision
For pathology groups that remain undecided about when and how to implement digital pathology, the CPT codes represent a positive development. This may eventually lead to digital pathology workflows becoming fully reimbursable and allow labs to monetize the cost of acquiring and using digital image scanners and systems.
The Dark Report’s sister publication, Dark Daily, noted in 2021 that a full-featured digital pathology scanner can cost $250,000 or more. Additionally, buying the systems needed to fully incorporate digital pathology into daily workflows can total $500,000 to $1 million.
Those expenses must figure into the bigger financial picture that any lab or pathology group tackles.
“Groups evaluating digital pathology need to consider if the cost structure make sense for the business,” Richard said. “Establishing a return on investment where efficiencies can be gained, and costs can be mitigated, is an important step in establishing appropriate expectations.”
With that in mind, Richard recommended pathology practices consider the following factors that tie into adoption of digital pathology tools and systems:
- Potential reductions in courier costs.
- Improved turnaround time and care for patients at rural hospitals and labs.
- Greater efficiency to offset higher workloads as retirements increase.
- Ability to facilitate use of artificial intelligence and thus improve the accuracy of diagnoses.
- Ability to establish flexible models for distributing work with a group.
History would suggest that the rate CMS eventually assigns to the new CPT codes will drop if digital pathology becomes the standard of care and upfront costs have stabilized, Richard noted.
“CMS may ask whether practices gained efficiency and saved costs from digital pathology. If the answer is yes, CMS may therefore reduce reimbursements previously established for any digital pathology-specific codes,” Richard hypothesized. “It’s not to put a dark cloud over the progress we’re making in this segment of our industry, but realistically we need to also consider how all of this could potentially evolve long term.”
Contact Giovanni Lujan, MD, at Giovanni.Lujan@osumc.edu and Diana Richard at firstname.lastname@example.org.
Digital Adoption May Help Pathologist Shortage
WITH HUNDREDS OF OPEN ANATOMIC PATHOLOGIT JOBS IN THE U.S., practices will need to lean on technology to create more efficiencies. (See TDR, “Eight Macro Trends for Clinical Labs in 2023,” Jan. 3, 2023.)
Digital pathology can help in this regard because of its ability to let pathologists remotely review cases regardless of their location.
“We have a shortage of physicians in the marketplace,” said Diana Richard, Senior Director of Pathology and Strategic Development at XIFIN. “If practices have a large number of pathologists on the retirement track and they’re struggling to recruit, digital pathology allows for additional efficiencies into workflows, and it enables the scaling of test volume.”
The 13 New CPT Codes for Digital Pathology
NOTE THAT EACH OF THESE CODES should be listed separately in claims in addition to the code for the primary procedure.
- 0751T—Digitization of glass microscope slides for Level II, surgical pathology, gross and microscopic examination.
- 0752T—Digitization of glass microscope slides for Level III, surgical pathology, gross and microscopic examination.
- 0753T—Digitization of glass microscope slides for Level IV, surgical pathology, gross and microscopic examination.
- 0754T—Digitization of glass microscope slides for Level V, surgical pathology, gross and microscopic examination.
- 0755T—Digitization of glass microscope slides for Level VI, surgical pathology, gross and microscopic examination.
- 0756T—Digitization of glass microscope slides for special stain, including interpretation and report, group I, for micro-organisms (e.g., acid fast, methenamine silver).
- 0757T—Digitization of glass microscope slides for special stain, including interpretation and report, group II, all other (e.g., iron, trichrome), except stain for micro-organisms, stains for enzymes constituents, or immunocytochemistry and immunohistochemistry.
- 0758T—Digitization of glass microscope slides for special stain, including interpretation and report, histochemical stain on frozen tissue block.
- 0759T—Digitization of glass microscope slides for special stain, including interpretation and report, group III, for enzymes constituents.
- 0760T—Digitization of glass microscope slides for immunohistochemistry or immunocytochemistry, per specimen, initial single antibody stain procedure.
- 0761T—Digitization of glass microscope slides for immunohistochemistry or immunocytochemistry, per specimen, each additional single antibody stain procedure.
- 0762T—Digitization of glass microscope slides for immunohistochemistry or immunocytochemistry, per specimen, each multiplex antibody stain procedure.
- 0763T—Digitization of glass microscope slides for morphometric analysis, tumor immunohistochemistry (e.g., Her-2/neu, ER, PR), quantitative or semiquantitative, per specimen, each additional single antibody stain procedure, manual.