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The AHA today expressed serious concerns with the Centers for Medicare & Medicaid Services’ proposal to significantly reduce the payment rate for “nonexcepted” services provided in off-campus provider-based departments under the physician fee schedule proposed rule for calendar year 2018. “Making such an adjustment in CY 2018 would be arbitrary and capricious, unreasonable and unsupported by existing data, and in violation of the Administrative Procedure Act,” wrote AHA Executive Vice President Tom Nickels. AHA also expressed concern that the data CMS will use to calculate 2018 payment rates for the clinical lab fee schedule under the proposed rule are unreliable and incomplete. “Given the expected Jan. 1, 2018 timeframe for implementing the new CLFS payment rates, we urge the agency to take immediate steps, outlined in our detailed comments, to address these concerns,” AHA said. Among other comments, the association expressed support for the agency’s proposals to add new codes to its list of approved Medicare telehealth services and to delay the appropriate use criteria requirements.