Reimbursement Position Statements

On August 26, 2015, the Advisory Panel on Clinical Diagnostic Laboratory Tests met for the first time, and made recommendations regarding pricing methodologies for new codes subject to pricing determinations for CY 2016. With respect to nine codes representing eight Multianalyte Assays with Algorithmic Analyses (MAAAs), the Panel recommended that CMS establish payment amounts for these tests using the gapfill methodology. On September 25th, the Centers for Medicare and Medicaid Services recommended that payment amounts for these tests be determined using the cross-walk methodology. The Coalition for 21st Century Medicine recommends that the Panel affirm its August 26th recommendation that CMS use gapfilling to establish payment amounts for the nine MAAA codes under review for CY 2016.

On behalf of the Coalition for 21st Century Medicine (the Coalition), we appreciate the opportunity to comment on the CY 2016 Hospital Outpatient Prospective Payment (OPPS) Proposed Rule. We are writing to comment on the Centers for Medicare & Medicaid Services (CMS) proposal to continue its policy of “conditionally packaging” certain clinical laboratory diagnostic tests listed on the Clinical Laboratory Fee Schedule (CLFS).