New Rules for CDLTs that Aren’t ADLTs Take Effect Jan. 1

Be aware of the new reporting requirements that apply for the next PAMA data reporting period starting in January 2022. Explanation: Section 3718 of the Coronavirus Aid, Relief and Economic Security (CARES) Act revises the Clinical Laboratory Fee Schedule (CLFS) requirements for clinical diagnostic laboratory tests (CDLTs) that aren’t considered advanced diagnostic laboratory tests (ADLTs). The CARES Act also revises the phase-in of payment reductions under the Medicare private payor rate-based CLFS.

The 3 PAMA Changes

There are three basic changes you need to know about:

1. The next data reporting period for CDLTs that aren’t ADLTs will be January 1, 2022 through March 31, 2022, and will be based on the original data collection period of January 1, 2019 through June 30, 2019;
2. After this data reporting period, the three-year data reporting cycle for CDLTs that aren’t ADLTs will resume, i.e., 2025, 2028, 2031, etc.; and
3. The statutory phase-in of payment reductions resulting from the private payor rate implementation is extended by an additional year, i.e., through CY 2024. There’s a 0.0 percent reduction for CY 2021, and payment may not be reduced by more than 15 percent for CYs 2022 through 2024, as compared to the prior year.