Coding and Reimbursement of Flow Cytometry

In the 2003 Physician Fee Schedule Proposed Rule, the Centers for Medicare and Medicaid Services (CMS) proposed revising the way it reimburses for the performance of flow cytometry services.  According to CMS, "the current coding scheme (payment on a per marker basis) may encourage the performance of more markers than may be medically necessary because the pathologist determines what markers to perform and when to perform them."  Further, CMS also stated that, "when flow cytometry is performed to diagnose lymphoma or leukemia, there is a single interpretation based on the quantification of all markers tested.  There is not an interpretation of each marker individually."

The College of American Pathologists, the American Society for Clinical Pathology, other professional associations, and members of the medical community disputed these notions.  Ultimately, however, a new coding scheme whereby a panel, as opposed to the previously-used per marker approach, was adopted.  When relative work value units (or RVUs) were assigned to the new codes (both the professional and technical components), the subsequent resuls was tremendous cuts - up to 70% for the professional component and 50% for the technical component of flow cytometry services.  These new reimbursement rates became effective January 1, 2005.

ACLA expressed concerned with the new payment levels for both the professional and technical components, especially with those values assigned to the new 2005 technical component codes for flow cytometry, Codes 88184 and 88185.  Due to the significance of these reductions, ACLA asked eight of its member companies that perform a large number of flow cytometry services to carefully review the clinical staff, equipment and supply cost inputs used by CMS to determine the practice expense values for the new technical component codes.  On January 3, 2005, ACLA submitted official written comments to CMS summarizing the results of the input provided by these eight member companies.  In doing so, ACLA urged CMS to recalculate these codes and correct the payment levels given the additional input.  ACLA asked CMS to make these changes as soon as possible and retroactive to January 1, 2005.

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