NASL issued a press release on Tuesday, September 26, 2017, expressing "significant concerns" regarding the Centers for Medicare & Medicaid’s (CMS) proposed CY2018 Medicare reimbursement rates for clinical laboratory tests under the Protecting Access to Medicare Act (PAMA) of 2014.
NASL Expresses “Significant Concern” with CMS’ Proposed Clinical Lab Reimbursement Rates
Proposed Rates Will Disproportionately Affect Lab Services for Medicare Patients in Long Term Care
Washington, DC – NASL Executive Vice President Cynthia Morton issued this statement on behalf of the National Association for the Support of Long Term Care (NASL) today, expressing the association’s significant concerns regarding the Centers for Medicare & Medicaid’s (CMS) proposed CY2018 Medicare reimbursement rates for clinical laboratory tests under the Protecting Access to Medicare Act (PAMA) of 2014.
NASL represents clinical laboratories that specialize in serving frail, elderly Medicare beneficiaries living in nursing facilities and homebound. These NASL companies are a highly specialized segment of the clinical laboratory industry, which provide services to enable physicians and other practitioners to obtain prompt and accurate clinical lab results for Medicare beneficiaries living in skilled nursing facilities, assisted living facilities or under the care of home health agencies. Serving this special and growing Medicare population requires a unique service model, which includes obtaining specimens at the patient’s bedside and then returning results just hours later. The results of these very basic lab tests are then used to diagnose, make care decisions and monitor the status of a wide range of conditions such as diabetes, cancer, heart disease, pneumonia, urinary infections, influenza and flu-like diseases, asthma, COPD and arthritis often times avoiding the need for unnecessary emergency room services and hospital readmission.
NASL member clinical lab companies, which include the largest of the specialized labs serving these beneficiaries, serve a disproportionate amount of Medicare beneficiaries relative to the broader clinical lab industry by virtue of Medicare being the predominant payer of services for nursing facility and homebound beneficiaries. Because of this, NASL member clinical labs will shoulder the brunt of these massive lab fee cuts due to the patient population they serve and their inability to “cost shift” to non-governmental payers and high costs tests.
In passing PAMA in 2014, Congress’ intent was to develop a market-based fee schedule that would provide savings and predictability for lab services – while maintaining Medicare beneficiaries’ access to clinical lab services. The proposed Calendar Year 2018 reimbursement rates are based on data from a very small percentage of the clinical laboratory industry as a result of how CMS ignored Congress’ intent to base rates on the commercial rates of all segments of labs serving Medicare beneficiaries. As a result, the proposed rates are so low that they threaten beneficiary access – an outcome completely contrary to Congressional intent and the result of a failed implementation by CMS. According to NASL Vice President and Chair of NASL’s Diagnostic Testing Committee Alan Morrison, “CMS’ actions will be devastating to almost all labs serving this highly vulnerable population and such dramatic cuts simply cannot be absorbed by these labs by reducing their costs.”
NASL joins with other clinical lab organizations including the American Clinical Laboratory Association and the National Independent Laboratory Association in recommending that CMS heed the responses of stakeholders and both delay and re-work this proposed rule.