First Data Collection Period for Clinical Laboratories Is July 1, 2015 to December 31, 2015 -

In the October 1, 2015 Federal Register, the Centers for Medicare & Medicaid Services (CMS) published a proposed rule outlining extensive revisions to Medicare reimbursement for clinical diagnostic laboratory tests (CDLTs) that are paid based on the Medicare Clinical Laboratory Fee Schedule (CLFS). A related CMS factsheet and a CMS FAQ are available. A National Provider Call on the proposed rule is scheduled for November 10, 2015 from 2-3 pm ET. Interested parties may submit comments on the proposed rule on or before November 24, 2015.

The proposed rule implements a portion of the Protecting Access to Medicare Act of 2014 (PAMA), which requires that CMS set CLFS payment rates based on the weighted median of private payor rates for CDLTs as reported by clinical laboratories to CMS. In order to set CLFS payment rates effective on January 1, 2017 using this new methodology, CMS proposes that clinical laboratories collect private payor payment data for the period from July 1, 2015 through December 31, 2015, and report this data to CMS by March 31, 2016. Thus, clinical laboratories must immediately take steps to interpret the provisions of the proposed rule, assess their CDLT revenues and prepare to implement applicable data collection and reporting processes, without the benefit of final regulations to establish the parameters of these requirements.