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ADVANCE Discourse: Lab

ACLA Comments to CMS

Published July 14, 2014 2:40 PM by Kerri Penno

In public comments presented to the CMS today, the American Clinical Laboratory Association (ACLA) provided input on various aspects of implementing relevant provisions of the Protecting Access to Medicare Act of 2014 ("PAMA"), which modifies the Medicare reimbursement rate methodology for lab services. 

"ACLA supports a measured and thoughtful analysis as well as robust stakeholder engagement in order to guarantee the new fee schedule continues to ensure adequate access to lab services for Medicare beneficiaries," said Alan Mertz, ACLA president.

ACLA's comments primarily focus on the need for CMS to develop or clarify definitions of several key terms, determine when private payor rates must be reported and for what timeframe, build a technology platform capable of accepting millions of discrete pieces of data, and establish coding processes for certain new tests.

A key definition identified by ACLA in its comments was "applicable laboratory" and ensuring that this encompasses the true private market. ACLA pointed out that the text of the statute, as well as Congress' intent, reflects that all major sectors of the laboratory market should be represented in reporting private payor rates, including independent laboratories and hospital outreach laboratories.

The way in which CMS defines the parameters, participants, methods, and timeframes for lab services payment rate and volume reporting, ACLA notes, will have a substantial impact on the rates that the Medicare program pays for clinical laboratory tests. It also has the potential to impact other payors' rates, as many private payors and state Medicaid programs base their reimbursement levels on Medicare rates. ACLA asserts that Medicare rates for lab services are best determined when payment and volume data reflect true market rates for clinical lab testing.

"Modifying the Medicare payment system for clinical laboratory services is a complex undertaking and ACLA is committed to ensuring the end result works for clinical labs, CMS, and Medicare beneficiaries," said Mertz. "Decisions made during this process will have a major impact on the clinical laboratory industry and the patients we serve, and it is important that those decisions work to promote ongoing diagnostic innovations and protect access to critical lab testing for Medicare beneficiaries."

To view ACLA's comments in their entirety, click here.

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