Health Care Financing Administration
Department of Health and Human Services
P.O. Box 26688
Baltimore, Maryland 21207-0488
Attention: HCFA-1005

Dear Sir/Madam:

The American Association for Clinical Chemistry (AACC) welcomes the opportunity to comment on the Health Care Financing Administration’s (HCFA’s) proposed rule implementing the provision of the Balanced Budget Act of 1997 that requires the establishment of a prospective payment system (PPS) for hospital outpatient services. This proposal, if adopted, would pay hospitals a single, fixed fee for treating outpatients suffering from an ailment or injury covered by one of the 346 ambulatory payment classification (APC) groups.

HCFA states that some hospital outpatient services, such as clinical diagnostic laboratory services, are excluded from the hospital outpatient PPS. These services were exempted, according to the agency, because Medicare pays the same fee for the service wherever it is performed. Thus, HCFA does not want to "disrupt an existing level playing field." AACC agrees with this decision. The government and Medicare contractors already have a number of mechanisms for controlling test utilization, including adjustments to the fee schedule, local medical review policies and the medical necessity guidelines. Therefore, it is unnecessary to bundle laboratory testing within APC groups.

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.




Stephen Kahn, PhD, DABCC


Page Access: