Fix PAMA, Don’t Change Laboratory Date of Service Rule, ASCP Urges CMS

Publication Date: Sep 27, 2019

In a September 24 letter to the Centers for Medicare and Medicaid Services (CMS) on the Medicare Hospital Outpatient Prospective Payment System Notice of Proposed Rulemaking, ASCP urged CMS not to undermine the ability of clinical laboratories to bill for their molecular pathology services. It also called on the Agency to utilize hospital laboratory payment data to fix flaws with the new Clinical Laboratory Fee Schedule (CLFS).

As mandated by Executive Order 13877, CMS proposed to require hospitals to make public their standard charges, including payer-specific negotiated payments, for each item or service provided at the hospital. Interestingly, negotiated payment data is precisely the kind of data CMS needs to factor into the CLFS to transform it into a market-rate based payment system. As a result, ASCP recommended that CMS require the reporting of price and volume information so that flaws with the CLFS can be addressed.

ASCP also commented on CMS’s proposals to modify the Laboratory Date of Service Policy. CMS outlined three proposals that were the subject of a recent ePolicy article. In general, these proposals involve requiring the hospital to bill for these services, rather than the laboratory. ASCP is concerned that this shift could make molecular pathology services more vulnerable to bundling (“packaging”) in future rulemaking. ASCP opposed CMS efforts to block clinical laboratories from billing for the molecular pathology diagnostic service they provide.

Other articles in the October 2019 ePolicy News:

ASCP Delegation Meets with FDA on LDT Oversight
Meaningful Participation Sought Under the QPP for Pathologists in 2020
ASCP Opposes E/M Proposal in Medicare Physician Fee Schedule
CDC Coordinates Investigation, Offers Healthcare Provider Resources Regarding Lung Disease Associated with Vaping
ASCP Expands List of Choosing Wisely Recommendations
Choosing Wisely Champions Recognized for Reducing Unnecessary Testing

To read more articles from ePolicy News click here.

For more information regarding ASCP's advocacy initiatives and policy positions, please contact ASCP's Center for Public Policy at (202) 408-1110.

ASCP ePolicy News is supported by an unrestricted grant from Hologic.

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