OIG Addresses Status of PAMA Implementation

Changes to Medicare Part B payment for lab tests mandated by the Protecting Access to Medicare Act of 2014 (PAMA) take effect on Jan. 1, 2018.  Less than 15 months from the deadline, the Office of Inspector General (OIG) just issued a report documenting the progress the Centers for Medicare and Medicaid Services (CMS) is making in implementing the new payment system.

The OIG report describes the progress CMS has made with regard to implementation tasks and what remains to be done. While some guidance on reporting procedures and requirements has been issued, more guidance regarding Advanced Diagnostic Laboratory Tests (ADLTs) is still outstanding. Advisory panel meetings have been held and CMS will continue to receive recommendations from the panel and subcommittees. The data collection system is undergoing testing and expected to be available within weeks for registration.

At this point, there are five things labs should be doing to get ready for the new Medicare Part B lab test payment system:

1. Familiarizing themselves with the Final PAMA Rule (See “CMS Responds Positively to Requested Changes in Final PAMA Rule,” LIR, July 7, 2016, p. 4);
2. Getting ready to register on the CMS’s new data collection system when registration begins later this month;
3. Looking out for the two sets of materials CMS intends to release by year’s end before reporting begins on Jan. 1, 2017:
   • Educational materials explaining the payer data reporting process; and
   • Guidance explaining the process to follow when applying to have CMS designate a test as an ADLT;
4. Preparing for the release of the preliminary lab test fee schedule in September 2017 and, if warranted, providing feedback on its accuracy; and
5. Being on the lookout for the final PAMA fee schedule which CMS intends to issue in November 2017.