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CMS-1403-FC
patients. According to the commenters, the elimination of
full reimbursement (that is, the PFS amount) for pathology
services provided by part-time pathologists would interfere
with the multi-disciplinary approach that the commenters
have chosen to best serve patients. One commenter asserted
that, despite the fact that the pathologist simply may bill
the Medicare program directly, Alternative 1 interferes
with the practice of medicine. The commenter asserted that
our proposal is equivalent to saying that a physician group
cannot hire a part-time pathologist as part of its
practice. The commenter contended that finding a
pathologist who would travel to its offices was not easy,
and that informing a pathologist that he or she can bill
Medicare directly from the group’s office provides no
incentive to the pathologist. This commenter predicted
that the approach outlined in Alternative 1 would force
pathology to revert to the traditional model of referring
physicians sending specimens to a laboratory and receiving
pathology reports, rather than communicating with the
pathologist directly. One commenter stated its belief
that, if we permit a pathologist to bill for professional
services directly, there is no reason for the pathologist
to travel to different physician’s offices if he or she can
collect the same amount for professional fees while working
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