The Protecting Access to Medicare Act (PAMA) was enacted in 2014 to replace the sustainable Growth rate (SGR) cuts each year. This law reformed the Medicare Clinical Laboratory Fee Schedule (CLFS) and set caps for reductions. Since PAMA was enacted, CMS has missed implementation deadlines and has been delayed over the past few years. The new implementation date is March 31, 2017 where laboratories will need to begin to report to CMS private market data. The Medicare CLFS pays on over 1,300 tests and over $8 billion per year. Before PAMA, the CLFS was facing major cuts in reimbursement. PAMA now phases in those cuts at 10% per year for the first three years and 15% per year from for the next three years. On June 17, 2016 the final rule was published by CMS for the Protecting Access to Medicare Act of 2014.
Under the final rule, laboratories and physician offices are required to report their private payor rates to CMS if they have more than $12,500 in Medicare revenues from laboratory services from the CLFS AND they receive more than 50 percent of their Medicare revenues from laboratory and physician services during a data collection period.
Laboratories will be required to collect private payor data from January 1, 2016 through June 30, 2016 and report it to CMS by March 31, 2017. CMS recently released a template for reporting this data. CMS will then post the new CLFS rates based on a median of the private payor rates in November 2017 that will go into effect on January 1, 2018.
APS’ IT department is working on gathering the various private payor data for our clients who are required to report their data to CMS. APS is actively pursuing the exact format and data elements that CMS is requiring be reported to them under PAMA. We will continue to work on this programming and reporting to make sure that each of our clients who fall in this category are meeting the reporting requirements. APS continues to participate in webinars on this topic and will continue to update our clients as more information is learned.