Potential New CMS COVID-19 Testing Policies & Pricing on the Horizon?

January 22, 2021 By: Quadax

CAP calls on CMS to cease policy on test turnaround time, reimburse appropriately

During a meeting with officials from the Centers for Medicare & Medicaid Services (CMS), the College of American Pathologists (CAP) called on the agency to cease implementing of its policy on COVID-19 test result turnaround time that became effective on January 1. Additionally, the CAP asked that CMS establish a new price for COVID-19 testing that ensures laboratories are reimbursed appropriately for the resources needed to perform the tests.

During the January 4 meeting, the CAP reiterated its previous arguments that CMS’ new pricing scheme cuts the payment despite the current fees being already inadequate in many parts of the country, where prompt testing already requires laboratories to use every available platform. The CMS’ policies unfairly penalize laboratories for delayed COVID-19 tests due to factors outside of their control, such as the availability of testing supplies needed to run the tests. Further, CAP officials said Medicare payment rates established for SARS-CoV-2 nucleic acid testing have been improperly valued. Testing done at local hospitals and clinics cannot always be “high throughput” and will typically have a higher (not lower) cost per test, the CAP said. The processes for determining the clinical laboratory test prices were not followed.

In a January 8 follow-up letter to the CMS, the CAP reiterated its request that the agency takes the following steps:

  • Cease implementation of the new payment scheme for COVID-19 tests as it is highly burdensome and counterproductive.
  • Withdraw HCPCS codes U0001, U0002, U0003, U0004, and U0005 and establish a new price for CPT code 87635 that ensures laboratories are reimbursed appropriately for the resources needed to perform the tests.
  • Establish a national payment rate for all SARS-CoV-2 nucleic acid testing equivalent to the current (2020 rate) for high-throughput tests.
  • Make the updated, increased price for CPT code 87635 retroactive to the date this CPT code was created and implemented (March 16, 2020).

In October 2020, the CMS issued a new policy (CMS-2020-1-R2) that lowered the base payment amount for both codes to $75, effective January 1, 2021. If laboratories completed the test within two calendar days from the date of specimen collection, a $25 payment would be added if most COVID-19 tests used high-throughput technology in the previous month were completed in two calendar days for all of their patients.

This information is posted directly from CAP’s January 20 Advocacy Update.

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