In a document detailing the data that CMS considered in taking its initial crack at pricing lab tests, the agency said that close to 2,000 "applicable laboratories" submitted around 5 million records.
According to the simulations it performed, allowing more labs to report would have decreased payments by around 20 percent.
However, from ACLA's point of view, the simulation only further proved that CMS' approach isn't inclusive of the entire lab market.
PAMA, signed into law in 2014, establishes a market-based pricing system for lab tests where Medicare payment for a test equals the weighted median of private payor rates.
In implementing a process for collecting the information needed to establish pricing, CMS said only "applicable labs" could report test payment rates and volumes from private payors.
"Lynch syndrome testing is a common test, and it appears that in 2016, almost no labs were billing the panel code and they were billing individual gene codes instead." Because 2018 pricing can't be cut by more than 10 percent, compared to what CMS paid in 2017, the agency proposed $722 for this code.