October 23, 2017: MGMA letter to CMS expressing concern about the Clinical Laboratory Fee Schedule (CLFS)

Oct. 23, 2017

The Honorable Seema Verma
Administrator
Centers for Medicare & Medicaid Services
Department of Health and Human Services
200 Independence Avenue, SW
Washington, D.C. 20201

Dear Administrator Verma:

The Medical Group Management Association (MGMA) appreciates the opportunity to submit comments on the preliminary Clinical Laboratory Fee Schedule (CLFS) rates for the calendar year 2018 posted by the Centers for Medicare & Medicaid Services (CMS) on Sept. 22, 2017. We are deeply concerned that, if finalized, draft CLFS rates will result in significantly reduced access to critical point-of-care laboratory testing for Medicare beneficiaries due to the problematic approach CMS took when implementing the Protecting Access to Medicare Act (PAMA) of 2014. We strongly urge CMS to modify the existing PAMA regulations through issuance of an interim final rule effective Dec. 1, 2017 that holds calendar year 2017 rates in place until CMS has conducted targeted market segment surveys (reference laboratories, physician office-based laboratories, independent laboratories, and hospital outreach laboratories) to ensure the integrity and accuracy of data. CMS has the authority to validate and adjust preliminary rates to ensure congressional intent is fulfilled and rates accurately reflect private market payments across all market segments.
  Read the full letter