Comments and Letters

  • ACLA Comments on Gapfill Reconsideration Period for BRCA 1 & 2

    January 24, 2014
    January 24, 2014 Mr. Marc Hartstein, Director Hospital and Ambulatory Policy Group Center for Medicare Centers for Medicare and Medicaid Services 7500 Security Boulevard Baltimore, Maryland 31344 MoPathGapfillInquiries@cms.hhs.gov RE: Notification of Reconsideration Period – 2013 Gapfill Payment Amounts Dear Marc, Please accept the comments of the American Clinical Laboratory Association (“ACLA”) on the Notification of Reconsideration Period – 2013 Gapfill Payment Amounts for molecularContinue Reading »...
  • ACLA Letter to CMS Regarding Gapfill Payment Rates for BRCA1 and BRCA2 Sequencing

    December 31, 2013
    Jonathan Blum Principal Deputy Administrator Centers for Medicare & Medicaid Services 7500 Security Boulevard Baltimore, MD 21244 Dear Mr. Blum: On behalf of the American Clinical Laboratory Association (“ACLA”), we are writing to express our strong objection to CMS’s recent action establishing a new reduced price for CPT code 81211 (BRCA1 and BRCA2 sequencing) as part of the gapfill price-setting process. As discussed below,Continue Reading »...
  • Comments on Proficiency Testing Referral Sanctions Proposed Rule

    November 15, 2013
    Ms. Marilyn Tavenner, Administrator Centers for Medicare & Medicaid Services Department of Health and Human Services Room 445-G, Hubert H. Humphrey Building 200 Independence Avenue SW Washington, DC 20201 RE: CMS-1443-P: Medicare Program; Prospective Payment System for Federally Qualified Health Centers; Changes to Contracting Policies for Rural Health Clinics; and Changes to Clinical Laboratory Improvement Amendments of 1988 Enforcement Actions for Proficiency Testing Referral;Continue Reading »...
  • Comments Regarding 2013 Final Gapfill Prices

    October 30, 2013
    Mr. Marc Hartstein, Director Hospital and Ambulatory Policy Group Center for Medicare Centers for Medicare and Medicaid Services 7500 Security Boulevard Baltimore, Maryland 21244 RE: Final 2013 Gapfill Payment Amounts for Molecular Pathology Tests Dear Marc, Please accept the comments of the American Clinical Laboratory Association (“ACLA”) on the final 2013 Gapfill Payment Amounts for Molecular Pathology Tests.1 ACLA is an association representing clinicalContinue Reading »...
  • Comments on CY 2014 CMS Preliminary Payment Determinations

    October 25, 2013
    Mr. Glenn McGuirk Acting Director, Hospital and Ambulatory Policy Group Centers for Medicare & Medicaid Services Center for Medicare 7500 Security Boulevard Mail Stop C4-01-26 Baltimore, Maryland 21244 Re: Centers for Medicare and Medicaid Services Calendar Year 2014 New and Reconsidered Clinical Laboratory Fee Schedule Test Codes and Preliminary Payment Determinations Dear Mr. McGuirk: On behalf of the American Clinical Laboratory Association (“ACLA”), weContinue Reading »...
  • Letter from 115 House of Reps to CMS

    October 07, 2013
    The Honorable Marilyn B. Tavenner Administrator Centers for Medicare and Medicaid Services U.S. Department of Health and Human Services Washington, DC  20201 Dear Administrator  Tavenner: We write to express our strong opposition to a proposal in the Centers for Medicare & Medicaid Services (CMS) proposed rule updating the Medicare physician fee schedule (PFS) rates and policies for calendar year (CY) 2014.  Under the 2014 Medicare PhysicianContinue Reading »...
  • Letter to Glenn Hackbarth Regarding MedPAC PFS Comments

    September 24, 2013
    Glenn M. Hackbarth, J.D., Chairman Medicare Payment Advisory Commission 425 Eye Street, NW, Suite 701 Washington, DC 20001 Dear Chairman Hackbarth: The American Clinical Laboratory Association is taking this opportunity to share our views on the recent comments submitted to the Centers for Medicare and Medicaid Services (“CMS”) by the Medicare Payment Advisory Commission (“MedPAC” or “the Commission”) with regard to the 2014 MedicareContinue Reading »...
  • Comments to CMS Regarding Lab Issues ESRD PPS

    August 30, 2013
    Laurence Wilson Director, Chronic Care Policy Group Center for Medicare Centers for Medicare and Medicaid Services 7500 Security Boulevard Baltimore, MD 21244 Dear Mr. Wilson: On behalf of the members of the American Clinical Laboratory Association (“ACLA”), many of whom provide services to end stage renal disease (“ESRD”) beneficiaries on renal dialysis, I am writing to express our concerns about post-regulatory issuances by theContinue Reading »...
  • Letter to Marilyn Tavenner regarding PFS Comments

    August 29, 2013
    Administrator Marilyn Tavenner 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: Medicare Program; Revisions to Payment Policies under the Physician Fee Schedule, Clinical Laboratory Fee Schedule, and Other Revisions to Part B for CY 2014, Proposed Rule (CMS-1600-P) Dear Ms. Tavenner, The American Clinical Laboratory AssociationContinue Reading »...
  • AIM Letter to Rep. Speier on Promoting Integrity in Medicare Act of 2013

    August 01, 2013
      The Honorable Jackie Speier U.S. House of Representatives 211 Cannon House Office Building Washington,DC 20515 Dear Representative Speier: On behalf of the members of the Alliance for Integrity in Medicare (AIM) — a broad coalition of medical specialty, laboratory, radiation oncology, and medical imaging groups committed to ending the practice of inappropriate physician self-referral — we thank you for introducing The Promoting IntegrityContinue Reading »...
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