Weekly Policy Update: CBSA Submits Comment Letter to CMS Advocating for Patient Access to Timely Precision Diagnostic Information

In July the Centers for Medicare and Medicaid Services (CMS) issued the CY 2020 Hospital Outpatient Prospective Payment System (HOPPS) Proposed Rule, which included concerning proposed revisions to the current Laboratory Date of Service (DOS) policy. After engaging our members about the potential impact of these changes, CBSA submitted a comment letter to CMS this week expressing that if finalized, the proposed revisions would significantly limit patient access to clinically important diagnostic testing information.

As the result of the Laboratory DOS policy that was included in the CY 2018 HOPPS Final Rule, our members have reported significant improvements in patient access to timely precision diagnostic information. By allowing laboratories to bill Medicare directly for these tests (rather than bundling with the hospital service if ordered within 14 days of discharge), the current policy gives patients quicker access to biomarker testing results that will help guide their treatment plan. There have been reports that prior to the 2018 Rule, hospitals would often wait 14 days before sending a specimen to a laboratory so the lab could bill Medicare directly and the hospital would not have to handle payment issues. For many patients, time to treatment is critical so creating unnecessary delays and barriers to clinically relevant information only makes it harder for patients to make an informed decision about whether a targeted therapy is appropriate.

CBSA is concerned that the proposed revisions will undo the progress that was made in the CY 2018 HOPPS Final Rule and will reinstate barriers for Medicare beneficiaries to access testing results and start the appropriate treatment.

While we applaud CMS for continuing to evaluate the current DOS policy, we hope the agency will consider the unintended consequences of these changes.

CBSA’s full comment letter can be found here.

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