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PAMA 2019 - Compliance Update




        RCM Enterprise Services is a reliable source for information needed to stay
        informed to current PAMA and CLFS requirements that are impacting the
        clinical laboratory. RCM revenue cycle experts monitor PAMA progress in
        pending lawsuits, congressional legislation, and regulatory misunderstandings.
        RCM laboratory consultants are ready to assist laboratories in understanding
        new regulations to stay compliant. We emphasized the financial integrity
        of the clinical lab well-being.

        With the PAMA Collection of data period coming to an end
        (January-June 2019), it is now time to review and analyze the data.
        A reminder of the current PAMA schedule:
           •  January – June 2019: Collect data
           •  July – December 2019: Analyze data
           •  January – March 2020: Report data

        Ask yourself the following questions:
           1. Do you have the reporting tools necessary to capture all of the
               necessary data elements? (Access the CLFS Data Reporting
               Template for reference at cms.gov PAMA Regulations/ Downloads)
               a.  CPT/HCPCs Codes
               b.  The private payor rate for each test for which final payment
                    has been made during the data collection period
               c.  Associated Volume for each test

           2.  Are you taking into consideration the necessary variables?
                a.  Have you filtered out non-applicable payors
                     (Medicaid Fee-for-Service, Other Government payors)?
                b.  Are all claims in your data fully adjudicated during the reporting period?

           3.  Have I reviewed all the more recent updates and CMS MLN Matters
                Newsletter SE19006, Article Release Date: February 27, 2019




                                          The data review and analysis
                                          should be done collaboratively
                                          in every organization by
                                          a multi-faceted team
                                          comprised of:
                                          Laboratory Account
                                          Receivable, Finance,
                                          Reporting, and Compliance.
                                          No single area nor staff member
                                          should review alone.







        Compliance Update
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