ACLA Submits Comments to CMS on Physician Fee Schedule, Clinical Laboratory Fee Schedule Calls For Adequate Reimbursement for Diagnostic Services

WASHINGTON D.C. – The American Clinical Laboratory Association (ACLA) submitted comments to the Centers for Medicare & Medicaid Services (CMS) urging the use of reimbursement policies that recognize the essential role of diagnostic services in the healthcare delivery system and protects access to these vital services for Medicare beneficiaries.

In July CMS issued a rule proposing revisions to payment policies for the Medicare Program in 2014, including changes to Physician Fee Schedule (PFS) reimbursement for anatomic pathology services, and proposed changes to the Clinical Laboratory Fee Schedule (CLFS) based on technological changes.

ACLA strongly opposes the proposed change to base payment for anatomic pathology services on Outpatient Prospective Payment System (OPPS) data. In the proposed rule CMS estimated this change would cut payment rates by an average of 26%, and some of the most common services would be cut by nearly 75%.

“The OPPS and PFS systems are hardly comparable, being derived through entirely different methodologies and for different purposes,” stated ACLA in its comments. “Not only does this proposal lack a sound policy basis, but it would discourage innovation and continued offering of certain assays by slashing reimbursement for tests that are vital to the treatment of Medicare beneficiaries with cancer and other serious diseases.”

ACLA also urged CMS to exercise great caution in its proposal to make changes to the CLFS based on technological changes, citing the cumulative impact of recent reductions to clinical laboratory reimbursement, including sequestration. ACLA expressed the importance of a collaborative process to review CLFS reimbursement.

“In reviewing these technological changes, it is essential that all parties – CMS, laboratories, and other interested members of the public – be involved in the development and refinement of the review process,” stated ACLA in its comments. “It is vital that this process be carried out transparently, consistently, and with the opportunity for meaningful involvement by the industry.”

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