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PAMA reporting delayed to 2021 with LAB Act passage

PAMA has initiated certain amendments with the collection period of January 2019 to June 2019. Although the LAB Act emphasizes to push the reporting window for this data out by one year, the extensive definition of the applicable laboratory that requires a multitude of entities to report this time around. In this article, we have laid out the revised reporting timeframes and the information that is required for your success during this critical period

Congress Passes LAB Act; PAMA Reporting Delayed by One Year
In a victory for clinical labs, Congress and President Trump and signed into law the Laboratory Access for Beneficiaries (LAB) Act before the year’s end as part of the 2020 spending bill. The move delays the next reporting cycle for the Protecting Access to Medicare Act (PAMA) to 2021.

The following notice was recently published by the Medicare Learning Network and is expected to be issued in MLN Matters next week:

Section 105(a) (1) of 2020 FCAA
The CDLTs (Clinical Diagnostic Laboratory Tests) (that are not the current Advanced Diagnostic Laboratory Tests (ADLTs), the data reporting schedule is expanded by one year. According to (Section 105(a) (1) of the Further Consolidated Appropriations Act of 2020 [FCAA]), the following schedule has been published by PAMA.

    1. CDLT data that was expected to be reported between January 1, 2020, and March 31, 2020, must now be reported from January 1, 2021, to March 31, 2021.
    2. Labs must publish data from the original data collection period of January 1, 2019, through June 30, 2019.
    3. Data reporting for these tests will recommence on a three-year cycle, beginning in 2024.

Section 105(a) (2) of FCAA
Moreover, the statutory phase-in provisions are modified and updated. For 2020, the rates for CDLTs (that are not ADLTs) or new CLDTs may not be subdued by more than 10% of the rates for 2019. There will be a 15% conversion cap for each of 2021, 2022, and 2023.

In a nutshell, private payer data for applicable clinical lab tests performed between January 1 and June 30 of 2019 is now supposed to be published to CMS from January 1 to March 30 of 2021 as an alternative of Q1 of 2020 for the original purpose.

Therefore, new payment rates that are obtained from the data are supposed to take effect in 2022, instead of 2021 legitimately. Then data reporting for CDLTs will pursue its three-year cycle and will occur again in 2024.

The act would also have a substantial impact on dataflow procedures. Therefore it would acquire a study to be conducted this year, to improve data collection and rate-setting to better represent Congress’ core intent of a market-based fee schedule for clinical laboratory services.

Effect of this ACT on clinical labs
This CMS method is referred to be as data flawed by many advocacy groups since their reporting requirements remarkably included independent and commercial labs while executing most hospital-based labs.

The expectations were made by clinical labs that; a more significant number of hospital labs would be reporting this time around with a rule amendment that required those utilizing a 14X type of bill to report now. Still, many of these labs had claimed that they were either ambiguous on the process or unwilling to report.

For example, after the initial reporting cycle in 2017, 75 percent of CLFS tests observed rate reductions, with 58 percent having phased-in declined due to an annual reduction cap that bounds a check from being dropped by more than 10 percent from the last year’s rate. That reduction cap increases to 15 percent in 2021.
There are chances that a study would be conducted to find a more suitable solution that complies with the standards for drawing payment data from across the industry while excluding the small sector.