Updated April 30, 2013

Accountable Care Organizations

• Comments to CMS on ACO Proposed Rule
  (June 3, 2009) (PDF, 150 K)
• Comments to OIG on ACO Waiver Designs
  (June 3, 2009) (PDF, 129 K)

Clinical Laboratory Fee Schedule

• Comments on New and Revised CPT Codes for 2009
  (PDF, 23 K)
• Comments on New and Revised CPT Codes for 2008
  (PDF, 30 K)

Comparitive Effectiveness Research

• Comments to the Institute of Medicine on Comparitive
  Effectiveness Research
  (April 13, 2009) (PDF, 149 K)
• Statement to the Federal Coordinating Council on Comparative
  Effectiveness Research
  (April 14, 2009) (PDF, 30 K)

Competitive Bidding

• Statement to the Centers for Medicare & Medicare Services on Competitive Bidding for Clinical Lab Service
  (July 25, 2007)

Cytology Proficiency Testing

• Letter to CMS on Proposed Cytology Proficiency Testing Regulation
  (March 16, 2009) (PDF, 2.4 MB)
• Statement to the Clinical Laboratory Improvement Advisory Committee
  (September 5, 2007) (PDF, 1.3 MB)
• Statement to the Clinical Laboratory Improvement Advisory Committee
  (June 20, 2006) (PDF, 48 K)
• Statement to the Clinical Laboratory Improvement Advisory Committee
  (September 7, 2005) (PDF, 354 K)

Genetics

• CAP Comments to the United States Patent and Trademark Office (PTO) on Independent Second Opinion Genetic Diagnostic Testing
  (March 26, 2012) (PDF, 180 K)
• Statement to the Food and Drug Administration on Ultra High Throughput Sequencing for Clinical Diagnostic Applications
  (July 22, 2011) (PDF, 46 K)
• Comments to FDA on Array-Based Cytogenetic Testing
  (July 30, 2010) (PDF, 94 K)
• Comments to NIH on Proposed Genetic Test Registry
  (July 12, 2010) (PDF, 75 K)
• Statement to the Secretary’s Advisory Committee on Genetics, Health and Society
  (March 27-28, 2006)
• Testimony to Medicare Evidence Development & Coverage Advisory Committee
  (February 25, 2009)
• Statement to the Centers for Medicare & Medicaid Services on Impact of Gene Patents on Medicine and Healthcare
  (October 30, 2007)
• Statement to the Secretary’s Advisory Committee on Genetics, Health and Society on an NAS Study
  (June 27, 2006)

Health Information Technology

• CAP Comments to CMS and ONC on Addressing Interoperability Challenges
  (April 22, 2013) (383 K)
• CAP Comments to ONC on Stage 3 Definition of Meaningful Use of Electronic Health Records
  (January 14, 2013) (769 K)
• CAP Comments to ONC on Stage 2 Meaningful Use Objectives
  (May 7, 2012) (398 K)
• Comments to ONC on Stage 2 Meaningful Use Notice of Proposed Rulemaking
  (May 7, 2012) (402 K)
• Comments to CMS on Stage 2 Meaningful Use Notice of Proposed Rulemaking
  (May 7, 2012) (372 K)
• Comments to HIT Standards Committee Implementation Workgroup’s request for Feedback on the Temporary Certification Program
  (June 13, 2011) (38 K)
• CAP Testimony Before the Meaningful Use Workgroup of the Health Information Technology Policy Committee
  (May 13, 2011) (356 K)
• Comments to ONC on Federal Health Information Strategic Plan 2011-2015
  (April 22, 2011) (269 K)
• Comments to ONC on Proposed Meaningful Use Stage 2 Objectives (February 25, 2011) (PDF, 175 K)
• Letter to Office of the National Coordinator for Health Information Technology on Certification Programs for Health Information Technology
  (May 5, 2010) (775 K)
• Letter to CMS on Electronic Health Record Incentive Program
  (March 2010) (327 K)
• CAP Testimony to HHS on Electronic Exchange of Laboratory Information
  (October 2009) (23 K)
• CAP Testimony on Electronic Laboratory Reporting to HHS
  (October 2009) (34 K)

Laboratory Developed Test

• Comments to FDA on RUO/IUO Draft Guidance
  (August 29, 2011) (262 K)
• CAP Comments to FDA on Oversight of Laboratory-Developed Tests
  (August 15, 2010) (152 K)
• Comments to SACGHS on Oversight Report
  (February 12, 2008) (32 K)
• Comments to SACGHS on Oversight Report
  (December 20, 2007) (543 K)
• Draft Guidance on In Vitro Diagnostic Multivariate Index Assays
  (July 26, 2007) (77 K)
• Powerpoint Presentation for SACGHS on CAP Accreditation of Genetics Testing Laboratories
  (March 26, 2007) (186 K)
• Comments to FDA on Analyte Specific Reagents Report
  (February 12, 2007) (175 K)

Medically Unlikely Edits

• Comments to Practicing Physicians Advisory Council on Medically Unlikely Edits
  (Aug. 27, 2007) (PDF, 47 K)
• Comments on Phase 4 of Medically Unlikely Edits
  (May 27, 2007)
• Comments to the Centers for Medicare & Medicaid Services on Medically Unlikely Edits
  (March 5, 2007)
• Response to a Medically Unlikely Edits proposal by the Centers for Medicare & Medicaid Services
  (January 8, 2007)

Miscellaneous

• Comments on SWGMDI Draft Report on “Increasing the Supply of Forensic Pathologists in the United States”
  (September 20, 2012) (PDF, 95 K)
• Comments to HHS on ANPRM on Human Subjects Research Protections
  (October 26, 2011) (PDF, 328 K)
• Comments to the National Quality Forum on The List of Serious Reportable Events
  (July 12, 2011) (PDF, 202 K)
• College of American Pathologists Follow-Up to Hematology & Pathology Device Panel October Meeting on Whole-Slide Digital Imaging
  (January 14, 2010) (PDF, 122 K)
• Comments to FDA’s Hematology and Pathology Devices Advisory Committee on Public Health Issues Related to the Use of Whole Slide Digital Imaging for Diagnostic Surgical Pathology
  (October, 2009) (PDF, 50 K)
• Comments to Health and Human Services Office of Inspector General on Modification of Safe Harbor Provisions
  (February 17, 2009) (PDF, 180 K)
• Comments to CMS on PT Referral Policy Addressing Sanctions for Unintentionally Referred Specimens
  (December 10, 2008) (PDF, 123 K)
• Comments to CMS on Validity of Pharmacogenetic Testing for
  Warfarin Metabolism
  (September 3, 2008) (PDF, 17 K)
• Comments to the Centers for Disease Control and Prevention on National Status Report 2007
  (June 30, 2008) (PDF, 764 K)

Patient Access to Test Results

• Comments on HHS Notice of Proposed Rulemaking (NPRM): “CLIA Program and HIPAA Privacy Rule; Patients’ Access to Test Reports”
  (November 14, 2011) (PDF, 1268 K)

Pay-for-Performance

• Comments to CMS on Developing the Physician Compare Website
  (November 30, 2010) (PDF, 110 K)

Personalized Health Care

• Comments to FDA on Companion Diagnostics Draft Guidance
  (October 12, 2011) (PDF, 128 K)
• Response to National Coordinator for Health IT’s Draft Detailed Personalized Healthcare Use Case
  (February 15, 2008) (55 K)

Physician Fee Schedule

• CAP Comments to CMS on Final Physician Fee Schedule
  (December 31, 2012) (262 K)
• Comments to CMS on 2013 Proposed Physician Fee Schedule
  (September 4, 2012) (276 K)
• Comments to CMS on 2012 Proposed Physician Fee Schedule
  (August 30, 2011) (138 K)
• CMS on Proposed Rule to Retract Signature Requirement
  (August 25, 2011) (100 K)
• Request to Delay Implementation of Requisition Signature Requirement
  (December 3, 2010) (PDF, 51 K)
• Comments on Proposed Revisions to Payment Policies Under the 2011 Physician Fee Schedule
  (August 24, 2010) (PDF, 68 K)
• Comments on the 2009 Final Self-Referral and Anti-Markup Provisions in Final Physician Fee Schedule
  (December 29, 2008) (PDF, 383 K)
• Comments on the 2009 Malpractice RVUs, Budget Neutrality Adjuster, PQRI and Update of High Cost Supplies in the Proposed Physician Fee Schedule
  (August 27, 2008) (PDF, 131 K)

Self-Referral

• Alliance in Integrity in Medicine Statement on GAO Report on Self-Referral of Advanced Imaging Services (November 1, 2012) (126 K)

Related Links

• Advocacy Issue Briefs
• Letters to Policymakers
• Testimony to Congress
• Information Packets
• Statline