The Florida Society of Pathologists (FSP) have submitted comments to the Medical Directors of First Coast Service Options (the regional Medicare carrier or MAC) concerning the proposed draft LCD (DL36324) as it relates to ordering necessary special stains.
They believe this LCD will hinder a pathologist’s diagnostic abilities in multiple ways by preventing the use of all available tools to achieve correct and definitive diagnosis. The Society maintains that only a rendering pathologist can bring together all aspects of the medical decision process that will ultimately provide positive patient outcomes.
According to the Society, the following 3 key areas within the proposed LCD are in need of revision;
1. Stains for H. pylori
The LCD attempts to dictate how and when stains are ordered. The Society believes this may delay appropriate diagnosing and care and the act of ordering such a stain should be left to the rendering pathologist.
2. Stains for infection in GE junction and esophageal biopsies
Society also believes the use of special stains for the identification of fungal esophagitis is extremely important and the LCD adversely affects the appropriate ordering of this crucial stain.
3. MSI and MSR staining
The LCD could limit the use of these stains just as the national standards continue to evolve.
APS will continue to monitor this issue and circulate updates to this policy.
APS has completely fulfilled all of our expectations, both in clinical pathology professional component billing and in all other areas of pathology billing.