LabReflex

# CMS Proposes Revaluing 88305 RVUs After Maryland Claims Analysis

## Summary
CMS is reconsidering RVUs for pathology codes 88305 and 88307 after the Maryland Health Care Commission analyzed 2023 all-payer claims data using CMS's own 25-minute intraservice time assumption. The analysis found 1,763 provider-days where 88305 alone implied more than 8 hours of work, and 587 days exceeding 24 hours. A 2016 Urban Institute pilot study (three sites) reported a 2-minute median intraservice time for 88305. CAP has scheduled an August 12 webinar on the proposed changes. The hosts argue the methodology ignores workflow reality — easy cases signed out quickly by dermatologists and gastroenterologists, with complex cases referred to pathologists — and call for the field to aggregate its own data to defend against sparse studies driving policy.

## Key takeaways
- CMS assigns 25 minutes of intraservice physician time to 88305 for RVU calculation; no time is submitted on claims.
- Maryland's 2023 APCD analysis multiplied 88305 volume by 25 minutes, producing 1,763 provider-days >8 hours and 587 >24 hours.
- The 2016 Urban Institute time-motion study (n=3 sites) found a 2-minute median for 88305 — used to argue 12–13x overpayment.
- Dermatology and GI clinicians often sign out easy 88305 cases (small biopsies) and refer complex cases to pathologists, skewing volume-time ratios.
- CAP announced the proposed revaluation and hosts a webinar August 12, 2026.
- The field lacks a centralized claims/outcome database to counter sparse studies; hosts suggest building one.

## Chapters
- Opening Studio Updates Personal Chat
- CAP Announcement CMS Fee Schedule
- Maryland Study Challenges 88305 Time
- CMS RVU Methodology Time Assumptions
- Maryland Letter 2016 Pilot Study
- Pathology Workflow Reality Check
- Provider Day Data Deep Dive
- CMS Next Steps August Webinar
- Field Needs Data Aggregation Strategy