September 8, 2017: MGMA to CMS: New laboratory payment initiatives could sideline POLs

September 8, 2017  

Seema Verma Administrator
Centers for Medicare & Medicaid Services
U.S. Department of Health and Human Services
Hubert H. Humphrey Building, Room 445–G 200
Independence Avenue, SW
Washington, DC 20201

Dear Administrator Verma:

The below signed organizations representing physicians from a number of different specialties thank the Center for Medicare and Medicaid Services (CMS) for its tireless efforts to implement the laboratory provisions of the Protecting Access to Medicare Act of 2014 (PAMA). However, the physician community is becoming increasingly concerned about the potential impacts of PAMA on patient access to critical rapid clinical testing services offered to patients while they are receiving medical care in their physician’s office.

Rapid, accurate patient testing in a physician’s office is invaluable to early diagnosis of a range of conditions. This type of testing plays a critical role in the treatment of acute illness, as well as in the ongoing management of chronic disease. It can also help avoid emergency care situations resulting in hospitalization. However, if the costs for providing these services at some point exceed the reimbursement for these tests, it will become impossible for these essential services to be provided to patients by their physicians when first presenting with a problem or during regular visits for ongoing management of disease. Initial projections on the impacts of PAMA on patient testing show significant cause for concern that this scenario may become reality when new PAMA payment rates are implemented on January 1, 2018.

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