08/28/98

Health Care Financing Administration
Department of Health and Human Services
Attention: HCFA-1913-IFC
P.O. Box 26688
Baltimore, Maryland 21207-0488

Dear Sir/Madam:

The American Association for Clinical Chemistry (AACC) welcomes the opportunity to comment on your May 12, 1998 interim final rule, which implements a number of Medicare billing changes for skilled nursing facilities (SNFs). Our comments are limited to the consolidated billing provisions of the interim rule.

V. Consolidated Billing

The Balanced Budget Act of 1997 requires the Health Care Financing Administration (HCFA) to establish a prospective payment system for SNF Part A services and consolidate billing for Part B services. Under the consolidated billing provision, SNFs are required to bill Medicare directly for all resident services, including laboratory testing. In the past, outside suppliers billed, and were reimbursed, by the federal health insurance program.

One of the concerns raised by HCFA is whether SNFs should be permitted to charge outside suppliers an administrative fee for processing the Medicare claim. The agency notes that if an outside supplier agrees to furnish services to the SNF for less than the applicable fee schedule amount, the SNF could retain the difference for each service billed to Medicare—thus creating a financial incentive for the SNF to provide unnecessary services.

AACC supports HCFA’s legislative approach, which would limit the SNF’s Part B payment to the lower of the applicable fee schedule amount or the amount that the supplier actually charges the SNF. We also share the Agency’s concerns regarding permitting SNFs to charge a "reasonable" administrative fee. If HCFA were to pursue that option, we recommend that the reasonable fee be proposed by HCFA and published for comment.

By way of background, AACC is the principal association of clinical chemists--professional laboratory scientists--including MDs, PhDs and medical technologists. AACC’s members develop and use chemical concepts, procedures, techniques and instrumentation in health-related investigations and work in hospitals, independent laboratories and the diagnostics industry nationwide. The AACC's objectives are to further the public interest and educational activities and help maintain high professional standards.

If we may be of any assistance, please call me at (708) 216-4725 or Vince Stine, Director, Government Affairs at (202) 835-8721.

Sincerely,

Stephen Kahn, PhD, DABCC

President

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