The Centers for Medicare and Medicaid Services (CMS) is moving forward with plans to begin individually reviewing all 1,250 codes on the Clinical Laboratory Fee Schedule (CLFS) and make adjustments based on “technological changes,” which includes tools, machines, supplies, labor, instruments, skills, techniques, and devices by which lab tests are produced and used. In the 2014 final Physician Fee Schedule rule, released Nov. 27, CMS said it would begin reviewing codes starting in 2015. In the proposed rule issued in July, CMS said it would start with the oldest codes and would review only tests that had been on the CLFS for at least five years. However, in the final rule, CMS indicated that it is not bound to adjusting oldest codes first and will consider volume, increasing utilization, and high-cost tests. Each year, the agency will conduct a data analysis of codes on the CLFS to determine which codes should be proposed during the rulemaking cycle for a payment adjustment due to technological changes. The American Clinical Laboratory Association (ACLA) believes the technology adjustment simply duplicates the current annual productivity adjustment used to modify pricing of CLFS tests. ACLA and other groups had requested a cap on any cuts […]
The Centers for Medicare and Medicaid Services (CMS) is moving forward with plans to begin individually reviewing all 1,250 codes on the Clinical Laboratory Fee Schedule (CLFS) and make adjustments based on “technological changes,” which includes tools, machines, supplies, labor, instruments, skills, techniques, and devices by which lab tests are produced and used.
In the 2014 final Physician Fee Schedule rule, released Nov. 27, CMS said it would begin reviewing codes starting in 2015. In the proposed rule issued in July, CMS said it would start with the oldest codes and would review only tests that had been on the CLFS for at least five years.
However, in the final rule, CMS indicated that it is not bound to adjusting oldest codes first and will consider volume, increasing utilization, and high-cost tests. Each year, the agency will conduct a data analysis of codes on the CLFS to determine which codes should be proposed during the rulemaking cycle for a payment adjustment due to technological changes.
The American Clinical Laboratory Association (ACLA) believes the technology adjustment simply duplicates the current annual productivity adjustment used to modify pricing of CLFS tests. ACLA and other groups had requested a cap on any cuts and had asked for a negotiated rulemaking so they could be involved in the discussions. CMS rejected virtually all comments, or failed to respond at all. The agency says a negotiated rulemaking would be a “time-consuming and resource intensive process” and that it “can accomplish the same purpose by utilizing the rulemaking process.”
