PHYSICIAN OFFICE LAB rates, and also expressed concerns that eliminating the having a uniform impact depending on where the tests bundled rate previously paid on individual tests typically are performed. CMS has responded to widespread critiperformed as part of panel needed to be re-instituted. cism of its data collection scope and method by expandCMS has only agreed to broaden laboratories eligible to ing labs eligible to report data under PAMA to include provide data in response to the GAO report. hospital outreach labs for the coming reporting period. It Reaction to PAMA in Conalso lowered the Medicare payment gress resulted in the introduction of amount to permit reporting by labs PAMA has galvanized H.R. 3584, The Laboratory Access with lower Medicare spend amounts. opinion across the for Beneficiaries Act (LAB) by Rep. Both moves were intended to palliate Scott Peters of California and five concerns that initial cuts were based laboratory and other representatives in June 2019. on only 1% of the labs performing clinical communities If passed, key provisions of this bill lab testing. In addition, legislation which have strongly would be to delay reporting of prihas been introduced in the House of opposed the cuts in vate pay reimbursement by one year Representatives to amend PAMA. reimbursement as too to delay further reimbursement cuts deep and not having and to refine the number and type of What can we expect in 2020? a uniform impact labs that will report data in the future. This year is the third and final year depending on where The bill is in both the house Energy in which cuts of up to 10% are the tests are performed. and Commerce and Ways and Means expected. Approximately half of the committees, but neither committee current CPT codes are expected to has taken action to move it forward. experience reimbursement cuts this year. Data collection between laboratories reporting reimbursement rates to CMS is scheduled to take place in the What are customers and the industry saying? first quarter of 2020 based on payments to them for lab Clinical laboratory organizations including the National tests in the first half of 2019. The results of CMS analysis Independent Laboratory Association (NILA) and Ameriof this data will be used to set rates for the three succeedcan Association for Clinical Chemistry (AACC) have ing years of PAMA, 2021-2023. expressed their concerns and in addition to supporting HR 3584 have encouraged their members to support the bill with their legislators. More than 50 other professional What are the key areas of organizations including pathology and medical care procontroversy surrounding PAMA? vider organizations have also expressed their concern. At PAMA has been met with widespread criticism on three the same time, the customer input I have become aware specific fronts by the clinical and laboratory communities: of has indicated some customers are reducing testing as a ʯ With only 1% of labs performing tests reporting result of “reimbursement concerns” but they are typically data for the initial collection period, concern is that not specifically mentioning PAMA as the reason. the largest laboratories’ data skewed market-based reimbursements toward the lower end of the scale ʯ The depth of cuts estimated as high as $670 million What should we consider doing to support our by CMS is substantially higher than estimated and clients’ lab testing and health care objectives? impact POL and other lower volume laboratories As always, making sure we have the important three-way diafar more than the larger reference laboratories logue with our key manufacturers and key customers is critical to assuring appropriate testing. Be sure to focus on clinical ʯ Access to care reductions, especially in rural areas value, keep your eyes and ears open for signals of concern, is a possibility use customer business reviews wisely and look for “scale up” opportunities to keep costs in line where needed. Stay alert The General Accounting Office, in a November 2018 and agile. PAMA is here, and your planning and focus are report, also challenged CMS to assure all eligible labokeys to maintaining and growing your lab business and supratories reported data, requested that CMS re-set future porting our customer needs for better patient care. rates based on actual payment rates rather than maximum
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February 2020
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