Pathology/Lab Coding Alert

Signing up may be half the battle.

Once you know you’re an “applicable lab” that must report Clinical Diagnostic Laboratory Test (CDLT) volume and payment rate data to Medicare, do you know how to get started?

We have the answers you need, as outlined in a Nov. 2 CMS data reporting webinar hosted by CMS Provider Communications Group moderator Diane Maupai. You can link to the webinar materials at www.cms.gov/npc.

Read on to learn about the Fee for Service Data Collection System (FFSDCS) you’ll use to report your data. You can register for the system via the CMS Enterprise Portal as of Nov. 14, and you’ll need to use the system to report data between Jan. 1, and March 31, 2017.

Zoom out: CMS published the final rule for implementing Section 216 of the Protecting Access to Medicare Act (PAMA) in the June 23, 2016 Federal Register. Under PAMA, Medicare must determine payment rates for tests paid on the Clinical Laboratory Fee Schedule (CLFS) based on a weighted median of current market prices charged by applicable labs that report their data to Medicare. CMS expects to implement the new rates starting January 1, 2018. For a detailed description of the rule, refer to “PAMA Finalized: Get Ready for Lab Price Reporting — And CLFS Overhaul” in Pathology/Lab Coding Alert Vol 17 no 9.

Penalty: If you’re required to report data to Medicare and don’t, you could be subject to civil monetary penalties of up to $10,000 per day. Not sure if you have to report data? Look to “Drill Down For More PAMA Guidance For Your Lab” on page 4 to answer that and other common questions.

Assign ‘Submitter’ and ‘Certifier’ From Your Lab

Before you start the process of registering to submit your lab’s data to Medicare, you need to assign two individuals within your lab to play two different roles in the data reporting process.

“Each reporting laboratory must have two distinct individuals registered in our system. The first is the data submitter, who will be entering in all of the data for the lab. The second is the data certifier,” explained Sarah Harding, from the CMS Division of Ambulatory Services in the Nov. 2 webinar.

Here’s why: PAMA requires that all data submitted from laboratories must be certified by a second individual from that lab.

After the submitter saves records in the system, the certifier must log into the system and review the data. “If any corrections are needed … the submitter will have to correct the data,” explained Ray Lee, CMS project manager for the development of CLFS reporting system.

Don’t miss: The certifier can’t change the file, and must review it again if the submitter changes it. Once the review is complete, the certifier will press the “certify all” button to submit the data.

Sign Up for CLFS Data Collection System

Registering your lab’s submitter and certifier to be able to submit data is a multi-step process.

Overview: “The first step to gaining access to our system is to register through the Enterprise Identity Management System, or EIDM,” said Harding. Once you register for EIDM, you’ll need to sign up for the FFSDCS. From there, “you’ll be able to request access to our specific data collection system for CLFS through the request catalogue,” Harding said.

That sounds easy enough, but the various steps require an authentication process that makes you wait before you’re allowed into the system, while CMS checks lab, submitter, and certifier credentials.

Here are the technical steps you’ll have to go through:

• Go to http://portal.cms.gov after Nov. 14, and register the submitter first.
• Register for a CMS EIDM username and password using information current within the CMS PECOS system. (Note that the CMS username and password is different from the CMS Enterprise User Administration [EUA] account)
• Request access to the FFSDCS as either submitter or certifier, and go through “a remote identity proofing process” as a security measure, according to Ray. “Then you will be asked to register a multifactor authentication token device,” and wait up to 72 hours for access.
• Come back to the portal, enter your credentials, and if you’ve been approved, “hover over the Fee-for-Service Data Collection System and click on the CLFS menu option,” Ray said.
• Begin the secondary registration process “to supply your laboratory name, your reporting tax identification number, as well as any NPIs that are associated to this reporting tax identification number, as well as any CMS certification numbers (CCNs),” Ray said.
• Save the info you’ve entered, and click the “Generate One Time Password” button, which will give you a string of characters that you must convey to the certifier.
• The certifier must go back to the portal and go through the registration process using the one time password (valid for one week) to link to the submitter and the lab.

Submit Data No Later Than March 31, 2017

You have two options for submitting data to the CLFS reporting system — via file upload or manual entry. Either way, you’ll be submitting data in a file with four columns: HCPCS code, payment rate (two decimal places), test volume, and NPI.

CMS provides a template in a program such as Excel. File upload is best for large data files, and uses a comma-separated file structure, according to Ray.

Important: “If an applicable laboratory has more than one payment rate for the same private payer for the same test, or more than one payment rate for different payers for the same test, the reporting entity will report each such payment rate and volume for the test at each such rate. The system will accept duplicate HCPCS codes within your submission,” Ray said.

Get Started Now

You can see that the process of submitting data for the CLFS payment system may be complicated. You should already have your data (PAMA requires your initial submission to be for payments received between Jan. 1 and June 10, 2016). So now is the time to go to the portal and begin the registration process. If you have more questions, read the following Q/A roundup, go to the helpful links therein, or contact the CLFS help desk at 844-876-0765 or clfshelpdesk@dcca.com.