Laboratory Public Meeting
Centers for Medicare and Medicaid Services, Baltimore, MD
Vickie Baselski, Ph.D., D(ABMM), F(AAM),
Chair, Committee on Professional Affairs
Public and Scientific Affairs Board
The American Society for Microbiology (ASM) appreciates the opportunity to provide comments to the Centers for Medicare & Medicaid Services (CMS) regarding payment methodology to be used for new codes which will be included in the 2007 Medicare Clinical Laboratory Fee Schedule, as announced in the Federal Register on May 26, 2006 [CMS-1324-N]. The ASM is the largest educational, professional, and scientific society dedicated to the advancement of the microbiological sciences and their application for the common good. The Society represents approximately 42,000 microbiologists, professionally employed as scientists and science administrators working in a variety of areas, including biomedical, environmental, and molecular fields as well as in clinical microbiology, clinical immunology, and molecular diagnostics.
Many of our members have primary involvement in clinical laboratory medicine including individuals directing clinical microbiology, immunology, and molecular diagnostic laboratories, individuals licensed or accredited to perform such testing, industry representatives marketing products for use, and researchers involved in developing and evaluating new technologies. Therefore, the ASM has significant interest in the process of establishing reasonable reimbursement for medically necessary laboratory testing to ensure quality patient care for Medicare beneficiaries.
Attached to this statement is a summary table outlining the ASM’s recommendations with respect to payment determinations for select new Current Procedural Terminology (CPT) codes to be included in the 2007 Medicare Clinical Laboratory Fee Schedule. Recommendations are based on the consensus of ASM’s Public and Scientific Affairs Board Committee on Professional Affairs and Committee on Laboratory Practices, which reviewed the “New Clinical Laboratory Tests for 2007” document on the CMS web site and provided comment. For each code, the following information is provided, as outlined in the May 26, 2006 Federal Register notice:
- New test code and descriptor
- Test purpose and method
- Test costs and charges (i.e. the National Limitation Amount)
- ASM recommendation on payment methodology
- Rationale for payment recommendation
ASM appreciates the opportunity to make recommendations on payment levels for new 2007 CPT codes. Should additional information or reference materials be required, ASM stands ready to assist in any way possible.