American Association for Clinical Chemistry
Better health through laboratory medicine
11/02/99

Health Care Financing Administration
Department of Health and Human Services
Attention: HCFA-4121-FC P.O.
Box 9013
Baltimore, Maryland 21244-9013


Dear Sir/Madam:

The American Association for Clinical Chemistry (AACC) welcomes the opportunity to comment on the September 30, 1999 final rule, which will permit providers, beneficiaries and other entities to appeal a Medicare Part B claim determination by telephone. Currently, such requests must be made in writing.

AACC supports HCFA's efforts to simplify the existing appeals process. Permitting laboratories and others to challenge a payment denial by phone should reduce the administrative burden on providers and speed up and streamline the agency's review process. We also agree with the six-month timeframe for initiating a review of a claim denial. Establishing separate timeframes for phone and written appeals would unnecessarily confuse beneficiaries and providers.

AACC also urges you to move as quickly as possible in making this option available through electronic means. Many providers, as well as beneficiaries, now have access to the internet. We believe this form of communication would eliminate delays, such as "busy signals," in contacting HCFA via the phone, while permitting providers and beneficiaries an easier method for transmitting data. Further, we believe the cost of using the internet would be negligible for those already with access to such services.

By way of background, AACC is the principal association of 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 to help maintain high professional standards. If you have any questions or we may be of any assistance, please call me at (405) 271-3571 or Vince Stine, Director, Government Affairs, at (202) 835-8721.

Sincerely,

 

K. Michael Parker, PhD
President