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CMS-1403-FC
on pathology reports or difficulty in asking follow-up
questions of pathologists at remote laboratories.
According to these commenters, by employing a pathologist,
a group practice is able to ensure that the pathologist is
a specialist in a particular practice area (for example,
gastroenterology), something the commenters asserted they
were unable to do with commercial laboratories.
A commenter expressed concern regarding Alternative 1
because, in the commenter’s view, it would unfairly limit a
specialty practice (such as gastroenterology or urology)
from billing and collecting the full global reimbursement
from the Medicare program for services rendered by an in-
office pathologist unless that pathologist works only for
that physician group. The commenter stated that it should
not matter if the pathologist works for more than one group
practice. This commenter expressed concern that
eliminating the in-office laboratory model would be a
detriment to Medicare beneficiaries. Another commenter
objected to our assertion that anatomic pathology services
provided in a physician’s office can result in
overutilization. The commenter expressed its view that
gastroenterologists do not overutilize anatomic pathology,
even when profiting from it, because a colon biopsy is much
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