Monday, July 8, 2019

Last Date to Comment to CMS re CLFS 2020 Pricing: I Commented on Posting Meeting Video

Today is the last day (day 14) to comment to CMS on pricing of new 2020 lab codes, relative to the public meeting held at CMS at Baltimore on June 24.

CMS requested comment on any of the 90 new codes presented, the several codes under appeal, and comment on how CMS should handle automated lab chemistry panel pricing, which was a special topic appended to end-of-day.

Comments go to a common mailbox at clfs_annual_public_meeting@cms.hhs.gov .

CMS Should Post & Archive the Live-Streamed Video

Let me mention I also submitted a comment specifically asking that CMS, which webstreams the meeting on YouTube, should ALSO archive the video on YouTube. 

CMS did this in 2016 and 2017, but not 2018, and I don't know if they will archive the meeting video now in June 2019.  I hope they do.   An example of a past-year archived video is here.

Action Point

If you agree, you could email CMS a short comment asking them to YouTube-archive CLFS meetings, as they used to do. 

I provide reasons below in a copy of my letter to them.   If you agree, sending even a one or two sentence comment on this point to CMS may help.

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(Comments requested by July 08).

To: CMS CLFS_Annual_Public_Meeting < clfs_annual_public_meeting@cms.hhs.gov >

Dear CMS Staff:

Thank you for the excellent organization of one of the largest CLFS public comment meetings, on June 24.

I strongly favor the practice in 2016 and 2017 of both streaming the CLFS meeting and also storing it as archived video on the CMS Youtube Channel.   

In 2018, for the first time, the meeting was live streamed but was not stored as archived video.

Storing as archived video has many advantages.  Some other CMS meetings are definitely stored that way.   New participants - which are common with new PLA codes - can look back to a recent meeting and understand the style and method of good presentations and improve theirs.   Different stakeholders can learn from one another.   Parties with a special interest in special types of codes - like infectious disease - can track only those sessions and do not need to commit to flying to Baltimore for just a few five minute presentations.   If CMS has issued preferences or instructions, people can confirm that they have understood them correctly.

In the past, I found the 2016 and 2017 archived video of both CLFS Public Comment and CDLT Advisory Board sessions to be very helpful.   Otherwise, a lot of information is lost or misunderstood.   

I hope CMS can archive online the June 24 CLFS presentation and the July presentations.

Thank you very much.

Bruce Quinn MD PhD
Bruce Quinn Associates LLC
Los Angeles and San Francisco