Here is an article on the MUE thing from CAP. It sounds scary. I hope to learn if it goes through soon, so I can get out of path and get into something where I'll be able to make real cash like general peds or family med. I can't believe I didn't know about this until now. We are totally F'd. This will crush private practice and academics alike.
CAP, Pathology Groups Mobilize Against MUEs
The College, in coalition with national and state pathology societies, is pressing the Centers for Medicare and Medicaid Services (CMS) to withdraw proposed severe limits on allowable units of service under Medicare.
The CAP and state and national pathology leaders have been conferring through conference calls in recent weeks to coordinate advocacy efforts, including a coalition letter to CMS in opposition to the units of service limitations, known as "medically unbelievable edits" (MUEs). In the series of calls, CAP President Thomas M. Sodeman, MD, worked with leaders of the Association of Directors of Anatomic and Surgical Pathology, Association of Pathology Chairs, American Pathology Foundation, the United States and Canadian Academy of Pathology and American Society for Clinical Pathology, American Society of Cytopathology, Association of Molecular Pathology and the National Association of Medical Examiners, as well as presidents of state pathology societies.
In their letter to CMS Administrator Mark McClellan, the groups will convey a unified message that the edits are grossly out of synch with standard medical practices and contradicted by abundant clinical evidence. The College is working with its scientific resource committees and coalition partners to gather clinical evidence for use in the response to the MUE proposal. The CAP also is expressing its concerns to Congress about the edits and the process CMS used to bring the MUE proposal forward.
The proposed edits, whose use will result in automatic denials of all claimed units in excess of the criteria units of service ceiling, are far-reaching: They affect the majority of pathology services and include CPT codes for all other specialties. While the proposed limit of two units for CPT 88305 (Level IVSurgical Pathology, Gross and Microscopic Exam) has drawn the greatest concern and attention in the pathology community, the MUEs will affect all areas of pathology, including the clinical side.
The College, in a Dec. 21 letter to McClellan, characterized the MUE proposal as "seriously flawed" and called on CMS to withdraw the plan for review by providers and others. The College pointed out that the volume of affected codesmore than 1,000demands more review time than the 60-day comment period CMS has provided. The due date for response is March 20, 2006; continue to watch STATLINE for updates on the comments process and further direction on how pathologists and others may oppose the MUE plan.
The MUE proposal also is drawing fire from the American Medical Association. In a Jan. 18 letter to McClellan, AMA Executive Vice President and Chief Executive Michael D. Maves, MD, called upon CMS to delay the proposed edits for six months, until January 2007.
"While we support reasonable steps toward error rate reduction, we have serious concerns with the July 1, 2006, [MUE] implementation deadline, as well as the manner in which the initiative has been rolled out," the AMA said, pointing out that the proposed MUEs are not the same as typical correct coding edits and should not have the same review period. "As opposed to updates for new and revised codes, a review of the entire CPT and HCPCS Level II code set for the MUE, in addition to being a much larger volume, is based on anatomic assumptions as to what is logical and, more problematic, CMS' expectations of what is medically reasonable."
Even a cursory review of the MUEs reveals a "large volume of errors that will require careful scrutiny," the AMA said. "This is particularly concerning since it was our understanding that these edits were to be set high enough that the Medicare contractors will not need modifiers to override the edits, however this appears not to be the case."
Also in the past two weeks, additional clarification was communicated to medical societies reviewing the edits. Specifically, CMS recommended that if a society disagrees with a proposed edit, it should submit clinical rationale to make its case, including medical records with patient-identifying information removed. CMS has not yet decided whether it will allow providers to appeal individual claims to their local carriers or fiscal intermediaries.
