Wednesday, October 2, 2019

Aegis Labs Protests CMS Proposal to Bundle $200 Tox Tests into Opioid Clinic Care

The new September 23,2019 issue of the Dark Report (subscription) has several articles on opioid drug toxicology monitoring as a growth area for labs (here). 

One topic I didn't see mentioned is Medicare's proposal to bundle tox testing costs (at immunoassay cup rates) into its new proposed payment bundle for Opioid Treatment Programs (OTPs). 


OTPs are shorthand for federally designated methadone clinics, although they can and may give other medication assisted drug treatments (e.g. buprenorphine) and counseling services. 

Given the opioid crisis, in October 2018 legislation, Congress created a new Medicare provider category for OTPs and provided guidelines for CMS to implement a bundled-payment benefit.

What CMS Proposed; Why AEGIS Is Unhappy 

This law, SUPPORT section 2005, is handled within this summer PFS rulemaking (here; a law firm's summary here).   CMS proposed to bundle immunoassay tox screening tests and any other toxicology testing into one low payment to the OTP.  (This is similar in concept to bundling lab tests into an ESRD monthly payment, or lab tests into an OPPS surgery visit).

If you want to get more up-to-speed on this, the best entry point I have found so far is the 30 page comment to CMS from AEGIS Labs, in the cloud here.  AEGIS is not happy.

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CMS payments for definitive tox tests (G0480-G0483) pay $114 to $247.  Presumptive test (80306) is about $17.

Small Share of Market

Medicare patients in OTP programs (essentially the methadone programs) would be a very tiny part of the national opioid use disorder market.  However, the theme of creeping bundling that may underfinance lab testing is an important theme.