CORRECTION

Correction: PAMA Relief—CMS 1450 14x TOB Labs DO Count!

Two articles appearing on the G2 website, “CMS Offers Some PAMA Relief But Not Nearly Enough” (G2 Compliance Advisor/Lab Compliance Advisor) and “2019 CLFS Offers Some PAMA Relief But Not Nearly Enough” (National Intelligence Report) contain two errors that we are correcting.

1. Rejection of 14X TOB Inclusion

The pieces say that CMS rejected the ACLA’s recommendation to include hospital outreach labs that use the Form CMS-1450 14x TOB to bill for non-patient lab services in the definition of “applicable laboratories.” The Final Rule actually does incorporate the recommendation. Accordingly, labs using the Form CMS-1450 14x TOB will count as “applicable” labs for the next data collection (Jan. 1, 2019 thru June 30, 2019) and data reporting (Jan. 1, 2020 thru March 30, 2020) periods, provided they get an NPI and meet the other regulatory requirements like the regulatory low expenditure threshold.

2. Wrong Legislation

While the description of CMS’s efforts to remain true to intent of the legislation in the subsection on industry’s response to the Final Rule is correct, the referenced legislation should have been PAMA, not the Affordable Care Act.

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G2 Intelligence would like to apologize for the errors, particularly the first which is of serious significance, and thank the user who pointed them out to us.

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