Swati Mehrotra, MD, Government Affairs and Economic Policy Committee

Gynecologic cytopathology will see significant reduction in physician work Relative Value Units (wRVU) according to Centers for Medicare and Medicaid Services (CMS) Final rule 2020.


The above codes were identified as potentially misvalued and reviewed by the RUC. The College of American Pathologists (CAP) recommended maintaining the current wRVU values at 0.42, which was accepted by the RUC. However, CMS disagreed with the RUC recommendations and recommended a wRVU value of 0.26 for all the above codes.

CMS noted that the intraservice and total times for codes 88141, G0124 and G0141 is decreasing from 16 to 10 minutes (-38%) and 16 to 12 minutes (-25%) for HCPCS code P3001. Hence CMS recommended wRVU of 0.26 based on their intraservice time ratio methodology and a crosswalk to CPT code 93313.

This translates into a 19% reduction in total NonFacility payment for the year 2020 per the CAP’s 2020 Physician Fee Schedule Impact Table. The reader is referred to Final rule 2020, CAP’s webinar handout and 2020 Impact Table for details. 


  1. Medicare Physician Fee Schedule: https://www.cap.org/advocacy/payments-for-pathology-services/medicare-physician-fee-schedule