Comments and Letters

  • Letter to Jon Blum Regarding Mitchell Study

    June 01, 2012
      June 1,2012   Jonathan D. Blum Centers for Medicare & Medicaid Services Director, Center for Medicare Management Mail Stop 314G 200 Independence Avenue, S.W. Washington, D.C. 20201   Dear Jon: Thank you very much for meeting with representatives of the College of American Pathologists and ACLA last week. We thought it was a very useful meeting and appreciated the opportunity to discuss pathologyContinue Reading »...
  • Comments to HHS on HPID and ICD-10 Extension Proposed Rule

    May 17, 2012
      May 17, 2012 Centers for Medicare and Medicaid Services Department of Health and Human Services Room 445-G Hubert H. Humphrey Building 200 Independence Avenue, SW Washington, DC 20201 Re: File Code CMS-0040-P RIN 0938-AQ13 Administrative Simplification: Adoption of a Standard for a Unique Health Plan Identifier; Addition to the National Provider Identifier Requirements; and a Change to the Compliance Date for ICD-10-CM andContinue Reading »...
  • Comments Regarding Taxable Medical Devices

    May 07, 2012
      May 7, 2012 Steven T. Miller Deputy Commissioner for Services and Enforcement Internal Revenue Service 1111 Constitution Avenue, NW Washington, DC Submitted electronically via www.regulations.gov (IRS REQ-i 13770-JO) Re:       Taxable Medical  Devices;  CC:PA:I2PD:PR  (REC—113770-10). Dear Deputy Commissioner Miller: On behalf of the American Clinical Laboratory Association (“ACLA”), I am pleased to provide these comments in connection with the Internal Revenue Service’s (“IRS”) Notice of ProposedContinue Reading »...
  • Letter to Chairman Pitts and Ranking Member Pallone Regarding MDUFA

    May 07, 2012
      May 7, 2012   The Honorable Joe Pitts Chairman Subcommittee on Health Committee on Energy and Commerce U.S. House of Representatives 2125, Rayburn House Office Building Washington, DC 20515 The Honorable Frank Pallone, Jr. Ranking Member Subcommittee on Health Committee on Energy and Commerce U.S. House of Representatives 2322-A, Rayburn House Office Building Washington, DC 20515   Dear Chairman Pitts and Ranking MemberContinue Reading »...
  • Comments on MU Stage 2

    May 04, 2012
      May 4, 2012 Ms. Marilyn Tavenner, Acting Administrator Centers for Medicare & Medicaid Services Department of Health and Human Services Attn: CMS-0044-P P.O. Box 8013 Baltimore, Maryland 21244-8013 RE: RIN 0938-AQ84: Medicare and Medicaid Programs; Electronic Health Record Incentive Program—Stage 2 Dear Ms. Tavenner: The American Clinical Laboratory Association (“ACLA”) appreciates the opportunity to comment on the Centers for Medicare & Medicaid Services’Continue Reading »...
  • Comments on EHR Certification 2014 Edition

    May 04, 2012
      May 4, 2012 Dr. Farzad Mostashari, National Coordinator for Health Information Technology Office of the National Coordinator for Health Information Technology Department of Health and Human Services Attn: 2014 Edition EHR Standards and Certification Criteria Proposed Rule Hubert H. Humphrey Building, Ste. 729D 200 Independence Avenue SW Washington, DC 20201 RE: RIN 0991-AB82: Health Information Technology: Standards, Implementation Specifications, and Certification Criteria forContinue Reading »...
  • Comments on Overpayments Proposed Rule

    April 16, 2012
      April 16, 2012 Ms. Marilyn Tavenner, Acting Administrator Centers for Medicare & Medicaid Services Department of Health and Human Services Attention: CMS-6037-P P.O. Box 8013 Baltimore, Maryland 21244-8013 RE: RIN 0938-AQ58: Medicare Program; Reporting and Returning Overpayments Dear Ms. Tavenner, The American Clinical Laboratory Association (“ACLA”) appreciates the opportunity to comment on the Centers for Medicare & Medicaid Services’ (“CMS’s” or “the agency’s”)Continue Reading »...
  • Comments Regarding Appropriate Use of Clinical Laboratory Testing

    April 04, 2012
      April 4, 2012 ACLA Comments on Choosing Wisely and Appropriate Use of Clinical Laboratory Testing Statement: The American Clinical Laboratory Association welcomes the Choosing Wisely effort and is now reviewing the report. We applaud continued efforts by physicians and medical groups to bring their expertise and evidence to bear in the effort to encourage appropriate utilization of medical testing. We note that mostContinue Reading »...
  • Letter to HHS on ICD-10 Implementation

    March 28, 2012
    March 28, 2012 The Honorable Kathleen Sebelius Secretary Department of Health and Human Services Room 445-G Hubert H. Humphrey Building 200 Independence Avenue, S.W. Washington, DC 20201 Re: ICD-10-CM Implementation Dear Secretary Sebelius, I am writing to you on behalf of the American Clinical Laboratory Association (ACLA) to urge the Department of Health and Human Services (HHS) to adopt several important recommendations as theContinue Reading »...
  • Letter to Reps Kind and Price Regarding Health Information Technology Reform Act

    March 14, 2012
      March 14, 2012 The Honorable Ron Kind 1406 Longworth House Office Building Washington, DC 20515 The Honorable Tom Price 403 Cannon House Office Building Washington, DC 20515 Dear Congressmen Kind and Price: On behalf of the American Clinical Laboratory Association (ACLA), I am writing in support of the Health Information Technology Reform Act, HR 4066, which seeks to exclude pathologists from incentive paymentsContinue Reading »...
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