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    Oct. 23, 2017  

    The Honorable Seema Verma 
    Administrator
    Centers for Medicare & Medicaid Services
    Department of Health and Human Services
    200 Independence Avenue, SW
    Washington, D.C. 20201

    Dear Administrator Verma:

    The Medical Group Management Association (MGMA) appreciates the opportunity to submit comments on the preliminary Clinical Laboratory Fee Schedule (CLFS) rates for the calendar year 2018 posted by the Centers for Medicare & Medicaid Services (CMS) on Sept. 22, 2017. We are deeply concerned that, if finalized, draft CLFS rates will result in significantly reduced access to critical point-of-care laboratory testing for Medicare beneficiaries due to the problematic approach CMS took when implementing the Protecting Access to Medicare Act (PAMA) of 2014. We strongly urge CMS to modify the existing PAMA regulations through issuance of an interim final rule effective Dec. 1, 2017 that holds calendar year 2017 rates in place until CMS has conducted targeted market segment surveys (reference laboratories, physician office-based laboratories, independent laboratories, and hospital outreach laboratories) to ensure the integrity and accuracy of data. CMS has the authority to validate and adjust preliminary rates to ensure congressional intent is fulfilled and rates accurately reflect private market payments across all market segments.
     

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