CLFS Talking Points

Here Are the Arguments When Commenting on 2018 CLFS Rates

ALL LABORATORY PROFESSIONALS AND pathologists are encouraged to submit comments to CMS before the Oct. 23, as well as send letters to their elected officials in Congress to urge both to delay and to fix the market price study and revise the proposed Clinical Laboratory Fee Schedule for 2018.

Beneficiaries Will Lose Out

Among the most important points to cover are these:

  1. The proposed rates are likely to cause Medicare beneficiaries to lose access to clinical lab tests.
  2. The rates are not based on market based price data, which is contrary to Congress’ intent.
  3. The weighted median that CMS used distorts the market-based price data.
  4. Labs struggled to comply with the rule, and, therefore, CMS did not have the full market-based price data needed to set rates accurately.

In these comments and letters, it is important to explain that the Part B lab test prices set under the Patient Access to Medicare Act may actually cause many Medicare beneficiaries—particularly those in nursing homes and in rural areas—to lose access to quality clinical lab testing.

The loss of access to lab tests by Medicare beneficiaries is important to mention because members of Congress should be open to any problems that could affect senior citizens in their districts. Similarly, CMS should be concerned about not being able to serve seniors in nursing homes, rural areas, and any other areas where labs might not be able to provide lab tests.

Another key point to make is that one reason the Part B lab test rates are so low is because the data CMS used to set these rates did not come from a representative sample of the clinical lab marketplace. In an announcement about his opposition to the rates, Quest Chairman, President, and CEO Steve Rusckowski noted that hospitals and physician office labs (POLs) comprise half of Medicare’s clinical lab testing volume and expenditures, but market-based pricing data from POLs and hospital labs make up only 8.5% of the data CMS used to calculate the CLFS rates for next year.

CMS’s use of a weighted median calculation instead of a weighted average when setting the rates distorted market value, said Xifin, a healthcare IT company. “We have presented data to show how radically pricing can be skewed with a weighted median calculation based solely on the mix of submitting providers,” Xifin said.

Distorted Market Value Data

Finally, because most labs struggled to comply with the rules CMS established for its data-collection effort, many did not submit data and others submitted inaccurate data, Xifin reported. Labs struggled in part because CMS did not publish the reporting criteria for data collection until after the data collection period closed.

Consequently, CMS did not receive private payer price data from a majority of the labs it required to report such data. In fact, CMS states that the private payer data it received from those labs that did report and that it used in its analysis came from only 0.7% of the nation’s labs!

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