CAP Urges CMS to Reconsider Payment for Software-Based Diagnostic Services

The College of American Pathologists (CAP) submitted comments to the Centers for Medicare & Medicaid Services (CMS) on Aug. 28 expressing concern with payment policies in the agency’s proposed 2027 Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems rule (CMS-1850-P).

CAP is particularly concerned that the proposed rule would remove software-based diagnostic services from the Clinical Laboratory Fee Schedule (CLFS) and is recommending to CMS that they remain classified as clinical laboratory services and continue to be paid under the CLFS.

In response to other requests for information, CAP also recommended that to improve hospital price transparency, CMS should standardize the requirements for “shoppable” services as those that patients can reasonably select and schedule in advance.

CAP also recommended that laboratory supplies be included in consideration of “critical medical supplies” as a vital part of strengthening domestic production of personal protective equipment in emergency public health preparedness. They also recommend that all laboratories, and not just those that operate as hospital departments, be included in the initiative.

Source:

https://www.cap.org/wp-content/uploads/2026/08/CAP-OPPS-CY2027-Comment-Letter-8-26-26-final.pdf?download=true