Citing adverse impacts to laboratories and patients, the CAP strongly advocated for improvements to how CMS collected data from laboratories. The CAP, along with other organizations within the laboratory community, met with Department of Health and Human Services (HHS) officials to urge the agency to delay the implementation of PAMA. The program rules excluded the vast majority of laboratories, including many hospital-based laboratories, from reporting private payer market data. Although most laboratories are excluded from reporting, the new CLFS rates will apply to all laboratories, including physician office laboratories, in 2018. The CAP sent the CMS additional comments that outline concerns from its members on October 23, 2017.