Tuesday, September 12, 2017

The OIG's Elaborate Reports on PAMA Implementation and on Current Lab Payments

PAMA requires not only that CMS implement a new system for payment of laboratory tests, but that the OIG provide annual reports on what CMS is doing.

Since the OIG has been issuing these reports in September, they may come out about now.   It's interesting to review how much material went into the September 2016 reports last fall.
  • The 17-page OIG report on how CMS is implementing PAMA - focusing on the June 2016 final rule - is here.
    • See also a relatively dry GAO report on the final rule; 5 pp; here.
  • CMS also issued an "HHS OIG DATA BRIEF," 15 pp, ton "2015 Year 2 Baseline Data," here.
I don't believe I'd seen the last-cited report until now.  HHS OIG produced some very interesting data cuts.  A quick sampling: 
  • Part B labs were $7B in 2015.   The top 25 tests were $4.1B.  Medicare paid substantially less in 2015 than in 2014 for genetic tests (primarily due to new controls on CYP testing).
  • Part B lab payments are highly concentrated.  1 % of labs (292/29,101 labs) received 54% of payments and 5% of labs received about 80% of payments.   95% of labs, then, got 20% of payments.
  • Payments for one traditional clinical chemistry test, 84443, TSH testing at $23 per test, garnered $475M - more than CMS paid for the range of molecular testing.