Advocacy Update

• CAP, CDC Announce Memorandum of Understanding for Surge Testing During Public Health Emergencies
• CDC Seeks to Increase Specimen Collections for Monkeypox
• 2021 MIPS Final Score Preview Now Available
• Last Week to Test Your June Advocacy Knowledge
• Editor’s Note: Next CAP Advocacy Update is July 12

The CAP signed a memorandum of understanding (MOU) with the Centers for Disease Control and Prevention (CDC) to provide assistance and expertise with diagnostic surge testing during public health emergencies. Based on experiences with the current COVID-19 pandemic and other disease outbreaks, the CDC values partnerships between public and private sectors to support a significant increase in demand for diagnostic testing during a public health emergency. Under the memorandum, the CAP will collaborate with the CDC, other partners, and government agencies to support surge testing capacity when public health emergencies and emerging public health threats arise.

“Pathologists have been on the frontline of the COVID-19 crisis, responsible for developing and selecting new test methodologies, validating, and approving testing for patient use, and expanding the testing capabilities of the communities they serve to meet urgent and evolving needs,” said CAP President Emily Volk, MD, FCAP. “The CAP has actively engaged with government agencies to lend its expertise on diagnostic testing issues throughout this pandemic. We now welcome the opportunity to formalize a partnership with the CDC and other government agencies to ensure the patients we serve in communities across the United States have access to the tests they need during public health emergencies.”

As part of the agreement, the CAP will serve as a communications hub between CAP member experts, CAP committees, and entities participating in the MOU. The CAP will leverage its accredited laboratories to assist external surge testing capacity. The CAP will also collect capability data from accredited laboratories to identify those with the capacity to support a national response, including community-based testing for vulnerable patient communities.

The CDC issued a Health Alert Network Health Update to announce updated case-finding guidance for monkeypox. Since May 2022, the CDC said monkeypox cases, which have historically been rare in the United States, have been identified in 18 states and territories among persons returning from international travel and their close contacts domestically.

During a recent call between the CDC, the CAP, and laboratory groups, agency officials noted there is sufficient testing capacity for monkeypox across the United States. However, the officials cited specimen collection as a concern.

In updated case-finding guidance, the CDC expanded its case definition to encourage testing for monkeypox among persons who present for care with relevant history, signs, and symptoms. In people with epidemiologic risk factors, rashes initially considered characteristic of more common infections (eg, varicella zoster, herpes, syphilis) should be carefully evaluated for concurrent characteristic monkeypox rash and considered for testing.

Please review the Health Alert Network Health Update in detail for more information.

Agencies Update Guidance for Monkeypox Virus Disposal

Interagency partners at the Transportation, Labor, and Defense departments, the Environmental Protection Agency, Centers for Disease Control & Prevention (CDC) updated planning guidance for handling category A solid waste, which includes the transportation and disposal of material suspected to contain monkeypox virus. Read the updated guidance document.

All currently known monkeypox cases in the United States are of the West African clade. If clinical teams can reasonably determine that it holds true for the specific patient, then materials known or suspected to contain only West African clade monkeypox virus can be classified at lower levels (ie, below Category A) under the Hazardous Materials Regulations (HMR). Waste can be packed, transported, treated/inactivated, and disposed of as United Nations (UN) 3291, Regulated Medical Waste (RMW) under the HMR and any applicable state, tribal, local, or territorial regulations—the same way other waste from health care facilities is routinely managed.

Laboratory specimens can be packed and shipped as Category B infectious substances (UN 3373, Biological Substance, Category B). Specimens suspected to contain only West African clade monkeypox virus do not require a Department of Transportation special permit.

The Centers for Medicare & Medicaid Services (CMS) opened the final score preview period for the Merit-based Incentive Payment System (MIPS). Authorized representatives of practices, virtual groups, and alternative payment model (APM) entities can now sign into the Quality Payment Program (QPP) website to preview 2021 MIPS final scores. The MIPS final score preview period is available until final performance feedback, including payment adjustments, is released in August 2022.

The preview period is a new phase of MIPS performance feedback that will provide clinicians with the opportunity to preview their final score prior to the release of payment adjustment information. As a reminder, your 2021 final score is what will determine your 2023 MIPS payment adjustment.

MIPS Scores and Large Pathology Practices

Large practices with more than 15 clinicians can no longer avoid penalties, or negative MIPS payment adjustments, using QPP measures reported through their billing companies. The CAP encourages large practices to reach out to the CAP to review options available for 2023 to ensure they can avoid future MIPS penalties. Further, large practices relying solely on the six pathology quality measures in the public domain for reporting in 2023 may not earn the points required to avoid a Medicare penalty in 2025. The CAP’s Pathologists Quality Registry can optimize a pathology practice’s MIPS scores. Email mips@cap.org for more information.

It’s the last week to test your June advocacy know-how. Last month over 130 members took the quiz. See how you compare against your fellow CAP members and brag about your top scores on social!   

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Your Advocacy Update newsletter will take a scheduled break July 5 for the Fourth of July holiday. The next issue will be on July 12, 2022. For more immediate updates, please check out our Twitter feed @CAPDCAdvocacy.