Though it remains to be seen what type of impact this report will have on dermatopathology provided by dermatology office labs, the Academy is concerned since the report carries implications for future legislative and regulatory actions designed to control growth and limit expenditures for self-referred pathology services. In the report, the Centers for Medicare and Medicaid Services (CMS) indicated its support for future cost-containment measures to address utilization growth and cost increases. And, on Aug. 1, Rep. Jackie Speier (D-Calif.) introduced a measure that would eliminate the Stark exception for in-office anatomic pathology services. To date, the Academy has been successful in explaining the integral role dermatopathology plays in dermatology, and will continue to advocate to preserve the ability of dermatologists to read their own pathology slides consistent with their training. However, the Academy is also calling on members to be vigilant stewards of appropriate dermatologic care.
There are many factors to consider when thinking about setting up a dermatopathology lab in your practice. While the Academy cannot advise members on a business decision for their individual practices, the chief concern when making that decision should always be whether it will improve the quality and efficiency of the care provided to patients. Other considerations may include a lab’s financial impact for a practice – which given the current payer and legislative environment may be hard to predict. When implementing and in-office lab, dermatologists and their staff also need to be aware of, and comply with, the full scope of complex federal and state laws and regulations governing the provision and billing of pathology laboratory services. They should also be mindful that, in certain instances, private payers may impose restrictive payment policies governing the provision of professional and/or technical dermatopathology lab services. They should also be aware that CMS and private payers may be monitoring dermatologists’ utilization of anatomic laboratory services to see if there is a significant change in utilization after in-house labs are implemented.
The Academy supports the principle of dermatology office labs, and continues to advocate to preserve dermatologists ability to read their own specimens or work closely with a dermatopathologist within the practice to provide more timely, effective, and integrated care. However, you should be aware that in the wake of the GAO report, the in-office lab model is facing significant scrutiny from Congress, where a bill that would remove the Stark exception, which allows this practice model, was recently introduced, as well as from CMS and private payers. Dermatologists working in a dermatology office lab along with the full practice team must ensure that the quality of the services they provide matches or exceeds that available from outside vendors.
The GAO report was commissioned by Congress to look at look Medicare claims utilization patterns and expenditure trends in physician self-referred and non-self-referred anatomic pathology services. The report’s recommendations for Congress and CMS and its request that CMS should explore further policy and regulatory options to control growth and limit expenditures pertain specifically to Medicare. However, utilization of dermatopathology services is also a concern for many private payers, which are considering their own strategies to reign in health care spending.
The AADA has reiterated its position that it is important to preserve the ability of dermatologists to read their own pathology slides consistent with their training and continues to advocate for this principle. Specifically, the AADA continues to vigorously communicate to Congress, regulators, and private payers the crucial importance of dermatopathology for dermatologic diagnosis and treatment. The Additionally, the AADA released a statement in response to the report expressing concern for the findings in the report, questioning some of its methodology, and asserting that dermatology must take thetakes seriously the issue of potential overutilization of in-office pathology services. seriously. The AADA also reiterated its position that it is important to preserve the ability of dermatologists to read their own pathology slides consistent with their training and continues to advocate for this principal.
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