The CAP has submitted comments on the Centers for Medicare & Medicaid Services’ (CMS) proposed 2027 Hospital Outpatient Prospective Payment System (OPPS) rule, highlighting concerns about payment policies for software-based diagnostic services, hospital price transparency requirements, and support for domestically sourced laboratory supplies.
Among the CAP’s recommendations:
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Software-based diagnostics: The CAP opposes removal of Software as a Medical Service (SaMS) technologies from the clinical laboratory fee schedule (CLFS). Algorithm-only analyses performed on laboratory data should remain classified and paid as clinical laboratory services. until an appropriate long-term payment solution is reached that remains budgetarily separate from the OPPS.
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Price transparency: Focus transparency requirements on services patients can reasonably compare and schedule in advance, recognizing that the scope and cost of many pathology services cannot be known until diagnostic evaluation is complete.
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Supply chain preparedness: Strengthen domestic production of personal protective equipment and include laboratory supplies and all types of clinical laboratories in the initiative.
Learn more: Read the CAP’s comment letter.