


|

Management & Compliance for Large/Academic Pathology Practices
|
Part 5 -
|
Organizational Models and Compliance Practices for Anatomic Pathology

Black-Schaffer & Johnson
|


Introduction - Organizational Models and Compliance Practices for Anatomic Pathology

Theory and practice of completely subspecialized diagnostic pathology
- Practical and applicable to any large practice,
with
- Particular commentary on implications for academic
practice

Nuts and bolts of correct coding for reimbursement and compliance
- Established criteria, and
- Emerging/controversial areas

Legal and regulatory framework of compliance
- Compliance planning for a pathology practice
- Why this makes sense to do
- How to do it efficiently

Process Improvement - Organization for Compliance and Efficiency

Pathology practice organization and operation

Academic and clinical responsibilities

Health care regulation and health care financing
- => are increasingly stringent

How can the leadership of a pathology practice enhance compliance
- => even while responding to pressure to operate
more efficiently?

Efficiency in the Practice of Anatomic Pathology

Clinical laboratories
- => factory industrial model
- => high fixed & low variable cost
- => high volume key to
efficiency

Anatomic pathology
- => cottage industry model
- => low fixed & high variable cost
- => low variability key to
efficiency

Decreased variability in anatomic pathology

Two Causes of Variability

Key concept - common vs. special cause variation:

Common cause variations
- - show apparently random distribution
- - result from intrinsic causes
- - present in every occurrence of process

Special cause variations
- - outside range of variability intrinsic to
process
- - can be assigned to extrinsic events
- - can be controlled, reduced, or eliminated

Subspecialization's Costs, Benefits, and Conditions

Subspecialization
- => diagnostic process with reduced special cause
variability

Decreased specimen input variability
- => increased specimen throughput and diagnostic
consistency

Cost of decreasing service variability
- => increased operational overhead and decreased
staffing flexibility

Increasing operational scale and staff size
- => offer increasing opportunities to decrease
service variability through subspecialization

Benefits of Subspecialization

Subspecialization in anatomic pathology can
- => increase productivity
- => decrease turn around time
- => enhance teaching of trainees
- => increase accuracy in diagnosis
- => promote clinical communication
- => facilitate faculty research
involvement
- => align diagnostic work with academic
interest
- => promote compliance in ordering and
coding

Subspecialization and Compliance

How can a compliance plan be synergistic with enhanced operational
efficiency?

Align diagnostic work with subspecialty expertise
- => diagnostic and operational benefits
- => also compliance plan benefits.

Subspecialization
- => conducive to understanding diagnostic issues
- => similarly conducive to understanding coding
and regulatory issues for subspecialized:
- diagnostic entities;
- specimen types;
- special studies.

Feasibility - Pathology Groups are Increasing in Size

Since 1994,
- Groups with <4 pathologists decreased by
23%
- Groups with 5-20 pathologists increased by
14%
- And the largest groups, those with greater than 20
pathologists, increased the most, by 60%

Desirability - is it Practically or Theoretically Sound to Subspecialize?

Practically,
- Maybe yes
- => Surgical pathology is a clearly defined subset
of anatomic pathology with well established clinical utility
- Maybe no
- => Surgical pathology is already most of what
most pathologists actually do

 Desirability - is it Practically or Theoretically Sound to Subspecialize?

Theoretically, In many large practices
- => general surgical pathology is
already
- => whatever is left over after subspecialists
have taken all the cases
- => on which generalist pathologists are no longer
allowed to have the last word

Economic Efficiency in Anatomic Pathology Practice is Professional
Efficiency
- Attempts to decrease unit cost in anatomic pathology
have typically focused on efficiency in technical (specimen processing and reporting) services
- These are economically a minor part of anatomic
pathology operations
- The major part is the professional time, effort, and
professional responsibility
- 70% of AP services in hospital setting, where less
than 3% of services generate technical component charges or payments
- 30% of AP services in commercial laboratory setting,
where only ~1/3 of global charges or payments are for technical component
- 1/3 of 30% TC ~10%; 2/3 of 30% plus 70% PC
~90%

Anatomic Pathology Practice Organization for Professional Efficiency
- Organizational change is necessary to leverage size
and achieve efficiency by subspecialization in anatomic pathology practices
- The rationale for this is evident from basic
business management principles but
- How does it work in practice:
- What are the obstacles?
- What is the benefit?
- Other outcomes?

Subspecialization's Biggest Obstacle
- THE MEASUREMENT OF PHYSICIAN WORK
- The biggest single obstacle to subspecialized
practice is ensuring equitable responsibilities among the pathologists in support of your practice
mission
- The biggest single equity issue that arises from
subspecialized practice is workload equity
- In a general diagnostic practice, if you work by
weeks, this can be hard enough when a week is a week is a week (because sometimes it's not)
- But when it becomes an issue not just of time on
service, but of how much time on which service
- How can you measure/assign work
equitably?

Measurement of Histopathologist Work - Both Volume and Complexity
- Specimens
- Number of specimens
- Type (group) of specimens
- CPT–4 total
- Slides
- Number of H&E slides
- Number of special stain slides
- Number of immunohistochemistry slides
- Reports
- Number of diagnoses
- Amount (items or units) of information reported
- Lines of diagnoses, templates, notes, gross and/or
microscopic descriptions

Measurement of Cytopathologist Work - Both Volume and Complexity
- GYN
- Number of specimens
- Source of specimens
- Nature of screened population
- Diagnostic threshold for cytopathologist review
- Non-GYN
- Number of specimens


- Type (group) of specimens
- Abnormality rate
- Special procedures
- Cytopathologist performance of FNAs

Subspecialization - Actual Service Work Measurement
- Considering the need to count specimens and also to
assess their complexity in various ways
- The first question is whether the work difference
among the various services is worth measuring
- To see an answer, let's delve into the actuality of
the last ten years of completely subspecialized diagnostic pathology at MGH
- We'll look at just how different the various
subspecialties are in terms of work done, as measured one way, in physician work RVUs.
- We'll consider alternative measures of work
shortly.

Subspecialization - More Actuality
- Various services have very different amounts of work
at any one time
-

 And these different amounts of work also
change a great deal over time

Subspecialization - The Requirement for Ongoing Measurement
- Services thus differ widely in amount of
work
- And these differences also change over
time
- Quantification can not be a one time
thing
- So, to minimize the administrative overhead of a
system to track the amount of work on each service, on an ongoing basis
- The system should do so as much as possible with
existing data and processes
- And should be carefully examined for potential
incidental benefits
- (Like compliance plan implementation)

Subspecialization - Empirical Efficiency
- We have doubled the overall amount of AP work at MGH
between 1995 and 2005
- How have we coped with this increased
volume?
- We have gradually worked out the intricacies of how
to assign work fairly, and, as we have done so, we have also realized substantial increases in
productivity.

 The following table and chart summarize
this increased productivity as measured by a far lower rate of increase in our staffing than in
diagnostic services as measured in RVUs.

Subspecialization - Empirical Efficiency

| FY1/2 | RVUs | Staff FTEs | Work Weeks | Work FTEs | RVUs/Wrk FTE | Alternative Wrk FTEs | Alternative Staff FTEs |
| 95#2 | 75,188 | 30.4 | 32.0 | 18.7 | 4,018 | 18.7 | 30.4 |
| 96#1 | 80,491 | 30.4 | 34.0 | 19.9 | 4,048 | 20.0 | 30.6 |
| 96#2 | 87,667 | 30.4 | 35.0 | 20.5 | 4,283 | 21.8 | 32.4 |
| 97#1 | 111,842 | 31.4 | 35.5 | 21.4 | 5,216 | 27.8 | 40.8 |
| 97#2 | 99,408 | 31.4 | 36.0 | 21.7 | 4,572 | 24.7 | 35.7 |
| 98#1 | 105,430 | 31.4 | 36.5 | 22.0 | 4,782 | 26.2 | 37.4 |
| 98#2 | 111,010 | 32.9 | 36.8 | 23.3 | 4,766 | 27.6 | 39.0 |
| 99#1 | 114,416 | 34.1 | 36.8 | 24.1 | 4,741 | 28.5 | 40.2 |
| 99#2 | 122,613 | 34.1 | 38.2 | 25.0 | 4,896 | 30.5 | 41.5 |
| 00#1 | 128,493 | 33.8 | 38.2 | 24.9 | 5,170 | 32.0 | 43.5 |
| 00#2 | 127,203 | 32.4 | 38.0 | 23.7 | 5,368 | 31.7 | 43.3 |
| 01#1 | 135,055 | 31.3 | 38.0 | 22.9 | 5,898 | 33.6 | 46.0 |
| 01#2 | 139,750 | 33.9 | 38.0 | 24.8 | 5,646 | 34.8 | 47.6 |
| 02#1 | 142,884 | 32.5 | 39.0 | 24.3 | 5,870 | 35.6 | 47.4 |
| 02#2 | 144,758 | 34.4 | 38.0 | 25.2 | 5,755 | 36.0 | 49.3 |
| 03#1 | 146,632 | 33.5 | 37.7 | 24.3 | 6,032 | 36.5 | 50.3 |
| 03#2 | 147,174 | 34.3 | 39.0 | 25.8 | 5,713 | 36.6 | 48.8 |
| 04#1 | 150,940 | 33.4 | 38.0 | 24.4 | 6,188 | 37.6 | 51.4 |
| 04#2 | 151,040 | 33.7 | 38.5 | 25.0 | 6,046 | 37.6 | 50.8 |
| 05#1 | 149,256 | 35.9 | 35.0 | 24.2 | 6,176 | 37.1 | 55.2 |
| Change | 99% | 18% | 9% | 29% | 54% | 99% | 81% |


Weeks –Nominal and Assigned per FTE


- 05#1 theoretical 35.0 weeks per FTE
nominal average 32.1
- of 32.1 nominal weeks per FTE actual assigned work
30.6

Weeks –Assigned and Actual per Staff Member
- 05#1 at theoretical 35.0 weeks assigned average 24.8
- of the 24.8 assigned weeks actual average work 23.0



Subspecialization - Various Quantitative Considerations
- As services become more distinctly differentiated
- => quantitative measurement of the work on each
service becomes more essential.
- Limitations of CMS RVUs include:
- Absence of established values for autopsy
services;
- Work contribution of, and supervisory effort for,
trainees;
- Differential increase efficiency with subspecialization
among:
- special study services,
- routine diagnostic services, and
- procedural / intraoperative services;
- Miscellaneous subspecialty specific factors.

Quantitative Considerations - CMS RVU
- CMS RVU advantages:
- => specific physician work component;
- => most prevalent single basis of
payment.
- Service work credited and allocated on RVU basis
- => close relationship between work credited and
payment received
- => simultaneously track physician work for
service credit and physician billing for compliance.

Quantitative Considerations - Autopsy
- Based on levels of work that were accepted as
equivalent by MGH staff on both the autopsy and surgical pathology services, relative values were
established for staff activities on the autopsy services in multiples of 88309:
- Service Description CPT RVUs
88309s
- Necropsy; with brain 88025
20.52 9.0
- Necropsy; without brain 88020
17.10 7.5
- Necropsy; stillborn/newborn 88029 11.40
5.0
- Necropsy; brain only 88037
6.84 3.0

Quantitative Considerations - Surgical Grossing
- Pathology services most conspicuously performed by
trainees under staff supervision
- => grossing of routine specimens in surgical
pathology.
- Equity with work directly done by staff in routine
cytopathology
- => 50% increment in cytopathology
credit.

Quantitative Considerations - Routine diagnostic surgical pathology services

| CPT | Narrative | RVU |
| 85060 | Blood smear interpretation | 0.45 |
| 85097 | Bone marrow interpretation | 0.94 |
| 88300 | Surgical path, gross | 0.08 |
| 88302 | Tissue exam by pathologist | 0.13 |
| 88304 | Tissue exam by pathologist | 0.22 |
| 88305 | Tissue exam by pathologist | 0.75 |
| 88307 | Tissue exam by pathologist | 1.59 |
| 88309 | Tissue exam by pathologist | 2.28 |
| 88321 | Microslide consultation | 1.30 |
| 88323 | Microslide consultation | 1.35 |
| 88325 | Comprehensive review of data | 2.22 |


Quantitative Considerations - Routine diagnostic cytopathology services

| CPT | Narrative | RVU |
| 88104 | Cytopathology, fluids | 0.56 |
| 88106 | Cytopathology, fluids | 0.56 |
| 88107 | Cytopathology, fluids | 0.76 |
| 88108 | Cytopath, concentrate tech | 0.56 |
| 88112 | Cytopath, cell enhance tech | 1.18 |
| 88125 | Forensic cytopathology | 0.26 |
| 88141 | Cytopath, c/v, interpret | 0.42 |
| 88160 | Cytopath smear, other source | 0.50 |
| 88162 | Cytopath smear, other source | 0.76 |
| 88173 | Cytopath eval, fna, report | 1.39 |


Quantitative Considerations - Special Studies
- Greatest increase in subspecialization
efficiency
- => services with most specialized
procedures:
- which special studies to order;
- how to evaluate, interpret, and report on the
results;
- how to code and bill for these services.
- We therefore decrement special study RVUs by 40% as
a more realistic measure of their relative time, effort and professional responsibility on subspecialized
diagnostic services.
- Prevalence of such special studies
- => differs widely among
subspecialties.

Quantitative Considerations - Special study services

| CPT | Narrative RVU |
| 88182 | Cell marker study | 0.77 |
| 88187 | Flowcytometry/read, 2-8 | 1.36 |
| 88188 | Flowcytometry/read, 9-15 | 1.69 |
| 88189 | Flowcytometry/read, 16 & > | 2.23 |
| 88291 | Cyto/molecular report | 0.52 |
| 88311 | Decalcify tissue | 0.24 |
| 88312 | Special stains | 0.54 |
| 88313 | Special stains | 0.24 |
| 88314 | Histochemical stain | 0.45 |
| 88318 | Chemical histochemistry | 0.42 |
| 88319 | Enzyme histochemistry | 0.53 |
| 88342 | Immunohistochemistry | 0.85 |
| 88346 | Immunofluorescent study | 0.86 |
| 88347 | Immunofluorescent study | 0.86 |
| 88348 | Electron microscopy | 1.51 |
| 88349 | Scanning electron microscopy | 0.76 |
| 88355 | Analysis, skeletal muscle | 1.85 |
| 88356 | Analysis, nerve | 3.02 |
| 88358 | Analysis, tumor | 0.95 |
| 88360 | Tumor immunohistochem/manual | 1.10 |
| 88361 | Immunohistochemistry, tumor | 0.94 |
| 88362 | Nerve teasing preparations | 2.17 |
| 88365 | Tissue hybridization | 0.93 |
| 88367 | Insitu hybridization, auto | 1.30 |
| 88368 | Insitu hybridization, manual | 1.40 |


Quantitative Considerations - Intraoperative and Procedural Services
- Time, effort, and professional responsibility of
some services
- => minimally decreased by
subspecialization.
- Particularly intraoperative and procedural
services:
- => performance and immediate evaluation of fine
needle aspiration biopsies;
- => intraoperative gross examination, touch
preparation, and frozen section examination.

Quantitative Considerations - Intraoperative and Procedural Services
- We therefore increment special study RVUs by 40% as
a more realistic measure of their relative time, effort and professional responsibility on subspecialized
diagnostic services.
- The prevalence of such services
- => also differs widely among
subspecialties.

Quantitative Considerations - Intraoperative and procedural services

| CPT | Narrative | RVU |
| 10021 | Fna w/o image | 1.27 |
| 10022 | Fna w/image | 1.27 |
| 88161 | Cytopath smear, other source | 0.50 |
| 88172 | Cytopathology eval of fna | 0.60 |
| 88329 | Path consult intraop | 0.67 |
| 88331 | Path consult intraop, 1 bloc | 1.19 |
| 88332 | Path consult intraop, add'l | 0.59 |
| 88333 | Intraop cyto path consult, 1 | 1.20 |
| 88334 | Intraop cyto path consult, 2 | 0.59 |


Quantitative Considerations - Service Impact of Systematic Adjustments
- Subspecialties differently affected by
- => special studies and/or
- => intraoperative & procedural
services
- => credit adjustments for services most affected
- => renal and hematopathology (down) and
- => FNA and FS (up).

Quantitative Considerations - Miscellaneous Factors
- Miscellaneous work factors:
- Call coverage (transplant, neuropathology, &c.),
- Interdepartmental subspecialty clinics and conferences
(breast multidisciplinary conferences, &c.),
- Changes in practice from those prevailing when RVUs were
established (synoptic reporting generally, and for excisional breast biopsies in particular; outside case
consultations with new NCCI edits, &c.), and
- Uniquely specialized services (obstetrical pathology
flotation of specimens with dissecting microscope examination for identification of villi,
&c.).

MGH AP Subspecialty Services - Service Credit and Staffing – 100% RVUs

| Subspecialty | Credit | Staff |
| Autopsy Path | 0.61 | 1 |
| Breast Path | 0.89 | 2 |
| Bone & Soft Tiss | 0.85 | 1 |
| Cardiac Path | 0.36 | 1 |
| Non-GYN Cyto | 2.33 | 2 |
| GYN Cyto | 0.53 | 1 |
| Dermatopath | 1.11 | 2 |
| Electron Micro | 0.13 | * |
| ENT Path | 1.28 | 1 |
| FNA Clinic | 0.47 | 1 |
| Frozen Sect Lab | 0.77 | 1 |
| GI Large Path | 0.81 | 1 |
| GI Small Path | 2.44 | 1 |
| GU Path | 1.10 | 1 |
| GYN Path | 0.80 | 2 |
| Hematopath | 1.54 | 1 |
| Neuropath | 0.91 | 1 |
| OB Path | 0.47 | 1 |
| Pulm Path | 0.51 | 1 |
| Renal Path | 0.30 | 1 |
| All Path | 23.13 | 23 |

*Electron microscopy staffed as add-on service.

Quantitative Considerations – Weighting of both Duration and Intensity of Service
- As above, based on intensity of service work as
measured in RVUs per week, we had a greater than 8:1 ratio of service work credit between the highest
credit service and the lowest credit service (GIS @ 2.44 : Renal Path @ 0.30)
- Staff signing out subspecialties with high weekly
credit had fewer weeks on service
- Staff on low weekly credit services acknowledged
their work was of lower intensity, but they also perceived they had less time free for academic
pursuits
- This led to the conclusion that we needed to weight
both the duration of service and the intensity of the service to achieve equitable distribution of
work
- We therefore needed to blend the credited work
between the simple duration of assigned coverage, which would provide the same credit per staff person
for regularly scheduled services, and the intensity of the work, which had become too extremely
variable
- Achieving a 4:1 maximum ratio of service work credit
between services for our mix of services meant weighting the duration (the weeks of coverage) at 30% and
the intensity (the RVUs per week) at 70%

MGH AP Subspecialty Services - Service Credit and Staffing – 70% RVUs and 30% Weeks

| Subspecialty | Credit | Staff |
| AUTOPSY PATH | 0.73 | 1 |
| BREAST PATH | 0.92 | 2 |
| BONE & SOFT TISS | 0.90 | 1 |
| CARDIAC PATH | 0.55 | 1 |
| NON-GYN CYTO | 1.93 | 2 |
| GYN CYTO | 0.67 | 1 |
| DERMATOPATH | 1.07 | 2 |
| ELECTRON MICRO | 0.13 | * |
| ENT PATH | 1.20 | 1 |
| FNA CLINIC | 0.63 | 1 |
| FROZEN SECT LAB | 0.84 | 1 |
| GI LARGE PATH | 0.87 | 1 |
| GI SMALL PATH | 2.01 | 1 |
| GU PATH | 1.07 | 1 |
| GYN PATH | 0.86 | 2 |
| HEMATOPATH | 1.38 | 1 |
| NEUROPATH | 0.94 | 1 |
| OB PATH | 0.63 | 1 |
| PULM PATH | 0.66 | 1 |
| RENAL PATH | 0.51 | 1 |
| ALL PATH | 23.13 | 23 |

*Electron microscopy staffed as add-on service.

Other Measurement Systems - Kim Units
- Few other systems to measure pathologist (rather
than pathology) work.
- Kim Units (KUs)
- For routine surgical specimens, KUs roughly parallel the
RVU physician work component at a conversion factor of 1 KU = 1.8 RVUs
- However, using this conversion factor:
Specimen Type KUs RVUs Difference
NON-GYN Cytology 1 1.0 88104 KUs = RVUs
GYN Cytology 2 2.7 88141 KUs >> RVUs
Autopsy Pathology 10 2.5 88309 KUs << MGH*
*KUs << than MGH (KP) values by factor of 3.7 (3.9)

Other Measurement Systems - Autopsy KUs
- At 10 units, KUs assign roughly 2.5 times the
relative credit to the physician work of an autopsy as CMS RVUs assign to an 88309.
- Service Description CPT RVUs
88309s
- Necropsy (KUs) N/A 5.70 2.5
KU

Other Measurement Systems – Kaiser Permanente & Kim Units for Histopathology
- "efficient and proficient ... pathologist"
(KP)
- 250 autopsies per year
- 2,500 pathologist work KUs (10 KUs/autopsy)
- 7,500 surgicals per year
- 15,750 pathologist work KUs (~2.1
KUs/surgical)
- "whole time equivalent consultant" (KU)
- ~10,000 pathologist work KUs
- 1,000 autopsies per year
- 4,760 surgicals per year

Other Measurement Systems – Kaiser Permanente & Kim Units for Cytopathology
- "efficient and proficient ... pathologist"
(KP)
- "review and sign out"
- 6,000 fine-needle aspirates per year
- 8,340 physician work RVUs (1.39 RVUs / FNA)
- "whole time equivalent consultant" (KU)
- microscopy and reporting of
- ~5,000 GYN cytology specimens
- 2,100 physician work RVUs (0.42 RVUs)
- microscopy and reporting of
- ~10,000 non-GYN cytology specimens
- 5,600 physician work RVUs (0.56 RVUs)

Other Measurement Systems - Royal College of Pathologists, London , England (RCP, 1992 & 1999)
- The 1992 and 1999 RCP workload guidelines were based
on annual case load: a combination of 4,000 surgical cases, 6,000 cytology cases, and 600 autopsy cases
per FTE direct clinical care pathologist in a district general hospital and half that in a teaching
hospital department
- A Special Advisory Committee on Histopathology
meeting in 2002 reconsidered these guidelines and determined they required substantial revision to take
account of the effects of increasing subspecialization, increasing use of more detailed minimum data sets
on cancer cases, increasing participation in multidisciplinary team meetings, and a general increase in
requirements for clinical governance, continuing professional development, and appraisal

Other Measurement Systems - Royal College of Pathologists, London , England (RCP, 2003 & 2005)

The sum of the Macroscopy and Microscopy scores from
the matrix below is considered to be the relative work of the service


| | Macroscopy |
| Microscopy | Low 1 | Intermediate 3 | High 5 | Very High 10 |
| Low 1 | 2 | 4 | 6 | 11 |
| Intermediate 3 | 4 | 6 | 8 | 13 |
| High 5 | 6 | 8 | 10 | 15 |
| Very High 10 | 11 | 13 | 15 | 20 |

- The expected rate of pathologist work is 10 of the
above units per hour, counting both Macroscopic and Microscopic work for cases where the pathologist does
both, and Microscopic only in cases where a resident or technician does the gross under the pathologist's
supervision
- A typical FTE direct clinical care pathologist would
be expected to provide approximately 40 weeks per year of diagnostic services, at 24 hours per week of
diagnostic services, which amounts to 9,600 units of diagnostic service
- Other direct clinical care activities would
typically include preparation for and participation in multidisciplinary team meetings, case reviews, and
second opinions
- Other supporting professional activities would
include teaching, continuing professional development, clinical governance, and research
- Specific examples of diagnostic services include the
following:

| Service description | RCP workload units acro+micro=score | CPT code | CMS professional component RVUs |
| Single small bx no level stain immuno | 1+1=2 | 88305 | 0.75 |
| Single small bx 1-4 levels stains immunos | 1+3=4 | 88305 to 88305+4*88342 | 0.75 to 0.75+4*0.85 = 0.75 to 4.15 |
| Single small bx >4 levels stains immunos | 1+5=6 | 88305 to 88305+>4*88342 | 0.75 to 0.75+>4*0.85 = 0.75 to >5 |
| Needle core bx no immuno | 1+3=4 | 88305 | 0.75 |
| Needle core bx with immuno | 1+5=6 | 88305+>1*88342 | 0.75+>0.85 = >1.6 |
| Frozen section (any indication) | 3+3=6 | 88331 or 88332 | 1.19 or 0.59 |
| BCC / SCC skin biopsy | 1+3=4 | 88305 | 0.75 |
| Melanoma skin biopsy | 1+5=6 | 88305 | 0.75 |
| Liver biopsy | 1+5=6 | 88307 | 1.59 |
| Nephrectomy for tumor | 5+5=10 | 88307 | 1,59 |
| Radical prostatectomy | 10+10=20 | 88309 | 2.28 |
| Cervical cytology | 2 | 88141 | 0.42 |
| Non-gyn cyto (1-3 slides) | 2 | 88160 | 0.50 |
| Non-gyn cyto (4-8 slides) | 3 | 88162 | 0.76 |
| Non-gyn cyto (>8 slides / complex case) | 5 | 88173 | 1.39 |
| Autopsy, low input | 1.5 hours = 15 units | | |
| Autopsy, intermed input | 3 hours = 30 units | | |
| Autopsy, high input | 6 hours = 60 units | | |


Other Measurement Systems – Canadian Experience (2005)
- Comparison survey of 27 Canadian pathology services
(with an 11.3% response rate)
- Survey data included the current and projected
optimal pathologist FTEs, annual number of anatomic pathology specimens (surgical, cytology and autopsy,
with sufficient detail to weight the former two), number of blocks and slides, and the patient population
served by the practice
- The anatomic pathology consultative procedures
(professional services) were categorized and weighted relative to the level IV surgical specimen as in
the following table

Individual Consultative Procedures

| Individual Consultative Procedures | Relative Weighting | CPT code - CMS professional component RVU - % of 88305 |
| Level I - Gross only examination | 14% | 88300 - 0.08 - 11% |
| Level II - Confirmation of normality by gross and microscopic examination of small specimens | 32% | 88302 - 0.13 - 17% |
| Level III - Confirmation of common degenerative, inflammatory and common benign conditions | 49% | 88304 - 0.22 - 29% |
| Level IV - Small specimens for diagnosis, including all endoscopic biopsy specimens and small organs removed for benign conditions | 100% | 88305 - 0.75 - 100% |
| Level V - Complex biopsy specimens or small whole organs, including specimens from specialized biopsies and excisions | 172% | 88307 - 1.59 - 212% |
| Level VI - Large complex organs, requiring extensive gross dissection and microscopic assessment | 253% | 88309 - 2.28 - 304% |
| Screening cytology (sputum and urine cytology, pathologist review of marked Pap smears) | 49% | 88141 - 0.42 - 56% |
| Diagnostic cytology (FNA, fluids) | 100% | 88112 - 1.18 - 157% 88173 - 1.39 - 185% |
| Intraoperative consultations (with and without frozen sections) | 150% | 88329 - 0.67 - 89% 88331 - 1.19 - 159% 88332 - 0.59 - 79% |
| Autopsy (full, uncomplicated) | 800% | |
| Intradepartmental consultation | 25% of level of specimen reviewed | 88321 - 1.30 - 173% |
| Consultation, review (e.g., cancer clinic reviews, for studies) | 66% of level of specimen reviewed | 88321 - 1.30 - 173% |
| Consultation, complicated (for difficult cases, external) | 150% of level of specimen reviewed | 88325 - 2.22 - 296% |
| Other procedures (e.g., FNA, bone marrow biopsy with or without aspiration) | As per other specialties or 100% of level IV | 10021 - 1.27 - 169% |

- Among all the parameters surveyed, the correlation
between the level IV equivalents as weighted above and the surveyed optimal FTE staffing was the best,
with a mean of 3,600 level IV equivalents per optimal FTE pathologist
- Quantitative Considerations - Major Drawbacks of Alternative
Systems
- 1) no explicit special study or procedure credit -
would fail to recognize large portion of some subspecialties' work;
- 2) information not already collected - would require
additional administrative procedures;
- 3) not directly related to billing - less effective
as compliance monitor.
- => For these reasons, despite some attractive
features of these alternative systems, MGH uses CMS RVUs, with adjustments as described.

MGH Completely Subspecialized Diagnostic Pathology - "Complete Subspecialization"
- 7/1/95 - diagnostic pathology at the MGH
- => complete subspecialization.
- "Complete" subspecialization?
- Not a particular mix / combination of organ /
disease oriented diagnostic services.
- A system in which each specimen comes directly to a
pathologist with particular interest and expertise in the organ or disease the specimen
represents
- => a system with no "general" diagnostic
service.

MGH Completely Subspecialized Diagnostic Pathology - Defined Subspecialties
- Developed list of diagnostic subspecialties usefully
covering all our specimens, as follows:
- Autopsy
- Bone &
- Soft Tissue
- Breast
- Cardiovascular
- Cytopathology (FNA)
- Cytopathology (GYN)
- Cytopathology (NON-GYN)
- Dermatopathology
- Electron Microscopy
- ENT
- Eye Frozen Section
- GI
- GU
- GYN
- Hematopathology
- Neuropathology
- Obstetric/Perinatal
- Pulmonary
- Renal

MGH Completely Subspecialized Diagnostic Pathology - Assigned Staff Subspecialties
- Each pathologist
- => chose five subspecialties and ranked them in
order of preference.
- Each subspecialty
- => assigned at least two pathologists.
- Each pathologist
- => assigned at most three
subspecialties.
- Work credit per week
- => assigned to each subspecialty
- => according to volume and complexity of
cases.

MGH Completely Subspecialized Diagnostic Pathology - Assigned Service Credits
- Net effect on number of staff to cover all
services
- => increase by one FTE.
- No increase in actual number of staff
- => increase (by one) in number of average credit
service weeks per FTE.
- Services less than average credit per
week
- => number of actual service weeks per FTE
potentially greater than number of average credit service weeks.

MGH Completely Subspecialized Diagnostic Pathology - Assigned/Tracked Specimens
- Each specimen accessioned to
- => appropriate subspecialty service with memo
(non-billing) fee code as flag to computer system.
- Number and characteristics of cases on each service
- => automatically tracked from subspecialty
flagged accessioning and billing data.
- Different colored tissue cassettes
- => track blocks and slides from each subspecialty
through histology.

MGH Completely Subspecialized Diagnostic Pathology - Scheduled Residents
- Residents' work reassigned to correspond with new
organization of specimen material
- => all services covered by same total number of
residents but
- => services (as for staff) more heterogeneous
so
- => PAs reassigned from general coverage to
assistance on the heavy grossing services
- (Bone and Soft Tissue, Breast, ENT, GI Large, and GYN
Large services).

MGH Rationale for Subspecialization - General
- Major competitive advantage for large or academic
medical centers - ability to offer subspecialized services, including diagnostic pathology
services.
- Integrated health care delivery systems -
infrastructure services to enhance value - minimize unit cost while optimizing clinical
performance.
- Clinical laboratory testing - decreased unit cost
with increased scale of operation.
- Increased efficiency in professional diagnostic
services - if associated with maintained or improved quality - also increases value.

MGH Rationale for Subspecialization - Pathology
- Patients go to referral facilities to consult
subspecialized clinicians
- => expectation is specimens will be diagnosed by
pathologists with similar expertise in their disease.
- With increasing clinical and pathology
sophistication
- => difficult for individual to maintain
literature familiarity and diagnostic competence in all areas of pathology.
- General diagnostic signout
- => pathologists encouraged to show difficult or
unusual cases to staff with appropriate subspecialty expertise.

MGH Rationale for Subspecialization - Diagnosis
- Significant diagnostic errors were rare but
- => increasing need to amend and reissue reports
lacking data required by clinician.
- Occasional cases
- => even very good general pathologists failed to
recognize need for subspecialty review.

Change in Surgical Pathology Corrected Diagnosis Rate

| | 1995 | 2002 | % Change |
| Surg Path Case | 45,208 | 71, 586 | +58% |
| All Revised Rep | 452 1.00% | 544 0.76% | -24% |
| Corrected Final | 50 0.11% | 27 0.04% | -66%* |

*p<0.001 Chi2

MGH Rationale for Subspecialization - Turn Around Time
- Frequency of intradepartmental consultations
increasing
- => decreasing both staff and resident
efficiency.


- For some specimen types
- => increasing turn around time due to frequent
need for subspecialized second opinion.

Turn Around Time - 1995 to 2005
- Surgical Pathology Turn Around Time

| Days | 1995 | 2003 | 2005 |
| Absolute | 2.9 | 2.7 | 2.9 |
| Adjusted* | 1.9 | 1.7 | 1.9 |

- *Adjustment allows 1 resident preview day (0.98), not
changed with subspecialization
- Differential between tech grossed and PA / resident
grossed specimens from 0.46-0.87 days (GYL-GYS to GIL-GIS)

MGH Rationale for Subspecialization - Communication and Collaboration
- Fifteen to twenty pathologists rotating on general
diagnostic services
- => hard to build relationships that facilitate
mutual understanding in difficult cases
- => better communication among smaller numbers of
similarly subspecialized clinicians and pathologists.
- Subspecialized clinicians working with
subspecialized pathologists
- => more likely to regard pathology subspecialists
as members of the subspecialty patient care "team."

MGH Rationale for Subspecialization - Academic Productivity and Support
- Closer relationship between pathology and clinical
subspecialists fosters academic collaboration.
- Pathologists with academic careers are better served
by concentrating on specimens in areas of interest.
- Quality of teaching and conferences improves with
subspecialization.

Change in Peer Reviewed Publication Record - 1995 to 2001

| Year | Staff | Publications | (Year) | Publications per Staff |
| 1995 | 43 | 155 | (1996) | 3.60 |
| 2001 | 44 | 159 | (2002) | 3.61 |

Includes publications cited in PubMed
Does not include CPCs or book chapters
Multiple authored publications counted once
Change in Grant Support - 1995 to 2003

| Service Rotations | N 1995 | N 2003 | >10% Grant Support 1995 | >10%Grant Support 2003 |
| Subspecialty | 12 | | 67% | |
| General | 31 | | 13% | |
| 1 | | 23 | | 52% |
| 2 | | 20 | | 30% |
| 3 | | 3 | | 0% |
| Total | 43 | 46 | 28% | 39% |


MGH Rationale for Subspecialization - Junior Residents
- Junior residents:
- => appreciate focused nature of
signout
- => learn effectively when exposed repeatedly to a
focused panel of specimens over the course of a rotation
- => enjoy not having to find and show cases to
subspecialists after general signout
- Junior resident concern:
- => sustaining ongoing exposure to all areas of
diagnostic pathology
- => MGH daily "Outs" conference:
- rotating subspecialties on MTW&F with good current
cases of all kinds every Thursday.

MGH Rationale for Subspecialization - Senior Residents
- Senior Residents:
- => appreciate the opportunities to focus on their
interests in various subspecialties
- => appreciate the availability of surgical
pathology fellowship type rotations in each area, either as resident electives or for post-residency
fellowships

MGH Rationale for Subspecialization - Staff Concerns
- Not seeing material from all diagnostic areas
- => those who stay in academic pathology have to
subspecialize for career development
- An increase in number of weeks on service
- => true only for a few subspecialists all of
whose services receive less than average credit and who do not "double up" signout
- => actual increases not sufficient to justify
return to general signout; addressed instead by weighting duration (weeks of coverage) at 30% and
intensity (RVUs per week) at 70%
- Increased senior staff responsibility for training
and supervising the junior staff
- => balanced by increased efficiency of signout
for senior staff in areas of expertise

MGH Pathology E-Mail Survey 10/03
- From your perspective, do you prefer the current MGH
system of AP subspecialization to that of general signout?

| | Responding | Yes | No | Undecided |
| Residents | 19 | 100% | 0% | 0% |
| Staff | 34 | 97% | 3% | 0% |

MGH Model for Subspecialization - Requirements
- Practice size - match useful range of specimen types
/ diagnostic entities with subspecialized pathologists;
- Commitment to academic mode of practice - exchange
broad general competence for narrower but deeper subspecialty expertise;
- Organizational support - administrative demands of
subspecialized practice greater than baseline requirements of pathology practice.
|


|
|
|