The role of pathologists is not clear in the proposed Medicare Shared Savings program for accountable care organizations, and the American Society for Clinical Pathology is asking for clarity.

More than that, the society in a comment letter on the proposed rule wants the definition of eligible physicians expanded to include diagnostic medical specialists. "The pathologists and laboratory professionals that staff our nation's laboratories represent the core of the diagnostic wing of the ACO, which is critical to prompt and efficacious patient diagnosis and treatment," according to the letter. "We note that three laboratory tests are performed for every imaging study."

Further, pathologists are best positioned to advance the goals of an ACO to reduce unnecessary and inappropriate testing, the society contends. "In fact, preventing the overuse and improper application of procedures is one of the many medical services performed by pathologists. When physicians order inappropriate or unnecessary laboratory tests, pathologists advise ordering clinicians of this fact and provide recommendations for appropriate test ordering."

Pathologists also have expertise that advances safe, effective and less costly treatment, all major goals of ACOs, according to the society. "For example, by testing metastatic colon cancer patients for the KRAS genetic mutation we can identify those patients that would suffer serious side effects and would not respond to standard cancer drugs. The projected savings from avoiding the use of these drugs is estimated at $700 million a year. In addition, breast cancer patients that are HER-2/neu positive do not respond to regular chemotherapy. Genetic testing, however, can identify these patients so they can be provided an alternative therapy. Appropriate therapies that are coupled to specific genetic testing can reduce the risk of death by 33 percent and the risk of recurrence by 52 percent while saving approximately $24,000 per patient. Many other tests reveal the value added by pathology and laboratory medicine."

Full text of the American Society for Clinical Pathology's comment letter on the Medicare Shared Savings program is available here.


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