Office-Based Lab Reporting Due May 30

Physician office-based laboratories that receive Medicare payments have a new financial reporting requirement to meet by May 30 (extended from the original March 31, 2017, deadline). The penalty for failure to report or for each misrepresentation or omission in reporting will be up to $10,000 per day.

The reporting rule comes from the Protecting Access to Medicare Act (PAMA), which directs the Centers for Medicare & Medicaid Services (CMS) to base Medicare payments for tests on the Clinical Laboratory Fee Schedule (CLFS) on rates paid by private payers. Laboratories are to collect, and report by May 30, private payer data from Jan. 1 through June 30, 2016. CMS will post the new Medicare CLFS rates — based on weighted median private payer rates and effective on Jan. 1, 2018 — in November 2017.

Physician office laboratories are required to report private payer rate and volume data if they:

  • Have more than $12,500 in Medicare revenue from laboratory services on the CLFS, and
  • Receive more than 50 percent of their Medicare revenue from laboratory and physician services during a data collection period.

CMS has created the CLFS Data Collection System with a data reporting template on the CMS PAMA Regulations webpage. To report applicable information, you must identify two separate employees: one to submit and one to certify your CLFS data. These two employees must (1) register in Medicare’s Enterprise Identity Management system, and (2) request either a CLFS submitter or a certifier role in the CLFS Data Collection System. The CLFS submitter must be certified in the Provider Enrollment, Chain and Ownership System (PECOS) as a “user” or “authorized user” on the PECOS Medicare Enrollment forms (CLFS submitters must have their name appear within one of the following 855 application forms: A,B,C,I, or R). 

For more information, see the CMS PAMA Regulations webpage and MLN Matters No. SE1619 (gives examples) and No. SE17002.

This deadline reminder appears in TMA’s Deadline for Doctors compliance tool. Bookmark it at www.texmed.org/Deadlines to help your practice stay on top of deadlines.

Published May 16, 2017

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Last Updated On

May 17, 2017

Originally Published On

May 16, 2017

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