Tuesday, October 29, 2019

CPT Calendar

I always find it hard to find the posting website for CPT codes during the brief period of public comment a month or two before each CPT meeting.   

For example, for the February 6-8, 2020, CPT meeting in San Francisco, code applications are due November 6, and Pathology proposal titles will be posted November 20, if you want to comment, you must request by November 29, and submit said comment by December 4.   (Non-pathology proposal titles will post December 6 with request to comment by January 16 and submitted by January 23.)

The overall calendar is posted here:

What's more tricky is finding the actual postings.  AMA creates a webpage to register the upcoming meeting (e.g. the February 2020 meeting), and when it creates THAT webpage, it will provide links to the inspection documents there.   For example, right now (October 2019), the CPT Overview Page provides notice the next meeting will be February 6-8, 2020, in SF, but doesn't provide any link to register and therefore doesn't provide any link to pre-meeting documentation.

As of October 29, AMA hadn't posted PLA deadlines for 2020, but they will be close to: January 10, April 10, July 10, October 10.   Applications through April 10 tend to appear in the summer CMS crosswalk/gapfill pricing meeting.

Clipped 10/29/2019:

Code Application deadlines

CPT® EDITORIAL PANEL MEETING DATE
LOCATION
SUBMISSION OF CODE APPLICATION DUE DATE
Feb. 6-8, 2020
San Francisco, California
Nov. 6, 2019
May 14-16, 2020
Chicago, Illinois
Feb. 12, 2020
Oct. 1-3, 2020
New Orleans, Louisiana
June 30, 2020
Calendar for upcoming meetings of the CPT® Editorial Panel

Pathology/Laboratory Application deadlines

*These deadlines refer to Pathology/Laboratory Applications only (Including Molecular Pathology, MAAA, GSP)
CPT® EDITORIAL PANEL MEETING DATE
LAB APPLICATION LISTING POSTED TO AMA WEBSITE*
LAB INTERESTED STAKEHOLDER REQUEST FOR APPLICATION MATERIALS DUE DATE*
LAB INTERESTED STAKEHOLDER WRITTEN COMMENTS DUE DATE
Feb. 6-8, 2020
Nov. 20, 2019
Nov. 29, 2019
Dec. 4, 2019
May 14-16, 2020
Feb. 20, 2020
Feb. 26, 2020
March 2, 2020
Oct. 1-3, 2020
July 8, 2020
July 24, 2020
July 31, 2020
Calendar for upcoming meetings of the CPT® Editorial Panel

Meeting agenda posting dates

CPT® EDITORIAL PANEL MEETING DATE
MEETING AGENDA POSTED TO AMA WEBSITE
INTERESTED STAKEHOLDER REQUEST FOR APPLICATION MATERIALS DUE DATE
Feb. 6-8, 2020
Dec. 6, 2019
Jan. 16, 2020
May 14-16, 2020
March 13, 2020
April 23, 2020
Oct. 1-3, 2020
July 31, 2020
Sept. 10, 2020
Calendar for upcoming meetings of the CPT® Editorial Panel

Summary of Panel Actions posting dates


CPT® EDITORIAL PANEL MEETING DATE
INTERESTED STAKEHOLDER WRITTEN COMMENTS DUE DATE
SUMMARY OF PANEL ACTIONS POSTED
Feb. 6-8, 2020
Jan. 23, 2020
March 9, 2020
May 14-16, 2020
April 30, 2020
June 15, 2020
Oct. 1-3, 2020
Sept. 17, 2020
Nov. 2, 2020


Monday, October 28, 2019

OIG to Study Urine Tox Billing in 2020

https://oig.hhs.gov/reports-and-publications/workplan/summary/wp-summary-0000404.asp


Review of Medicare Part B Urine Drug Testing Services

Medicare covers treatment services for substance use disorders (SUDs), such as inpatient and outpatient services when they are reasonable and necessary. SUDs occur when the recurrent use of alcohol or other drugs causes clinically significant impairment, including health problems, disability, and failure to meet major responsibilities at work, school, or home. Medicare also covers clinical laboratory services, including urine drug testing (UDT), under Part B. Physicians use UDT to detect the presence or absence of drugs or to identify specific drugs in urine samples. A patient in active treatment for an SUD or being monitored during different phases of recovery from an SUD may undergo medical management for a variety of medical conditions. UDT results influence treatment and level-of-care decisions for individuals with SUDs. The 2018 Medicare fee-for-service improper payment data showed that laboratory testing, including UDT, had an improper payment rate of almost 30 percent, and that the overpayment rate for definitive drug testing for 22 or more drug classes was 71.7 percent. We will review UDT services for Medicare beneficiaries with SUD-related diagnoses to determine whether those services were allowable in accordance with Medicare requirements.
Announced or RevisedAgencyTitleComponentReport Number(s)Expected Issue Date (FY)
October 2019Centers for Medicare & Medicaid ServicesReview of Medicare Part B Urine Drug Testing ServicesOffice of Audit ServicesW-00-20-358292020

Wednesday, October 23, 2019

Evidera Publishes Set of Open Access RWE Articles

Evidera, which is part of a CRO, publishes set of articles on Real World Evidence.

https://www.evidera.com/thought-leadership/our-publication-the-evidence-forum/

Evidera's biannual publication addresses the scientific, strategic, and operational challenges of today's healthcare environment, providing a forum for the exchange of thoughts and ideas focused on evidence and value. In this issue you can read content related to the relevant issues facing companies along the path to approval and access.

In This Issue

Read Now

Tuesday, October 22, 2019

OIG Annual Report on CLFS is Late (Fall 2019)

PAMA requires OIG to produce an annual report on CLFS payments.  This typically appear in September for the prior year (September 2018 for CY2017, etc.)

For example, "Medicare Payments for Clinical Diagnostic Laboratory Tests in 2017: Year 4 of Baseline Data" is here.

As of October 22, 2019, we are still waiting for the CY2018 report.


How Much Space Does We Work Have?

According to an Wikipedia, WeWork currently managed 47 million square feet at end-2018; according to an informational video at WSJ and a public blog, they had 528 locations as of summer 2019.

With 43,500 square feet to an acre, that is 1080 acres.

With 640 acres to the square mile, that is 1.7 square miles.

___

According to a website, they have raised around $8B in capital and according to 10/21/2019 news reports, have a valuation of about $8B.    Reportedly around summer 2019 they were losing about $200,000 an hour.




Friday, October 18, 2019

MolDx Test Panel Alert M101 (Cloud Copy; 10/2019)


Parent article here:  http://www.discoveriesinhealthpolicy.com/2019/10/hold-on-to-your-hats-moldx-publishes.html

Cloud copy in 10/2019 of M00101:

https://palmettogba.com/palmetto/MolDX.nsf/docsCat/MolDx%20Website~MolDx~Browse%20By%20Topic~General~Molecular%20Test%20Panel%20Edit%20Alert%20(M00101%20V4)?OpenDocument&Click=


Molecular Test Panel Edit Alert (M00101, V4)

MolDX CPT code range affected: 81161-81408
Test Panel Definition: A predetermined set of medical tests composed of individual laboratory tests, related by medical condition, specimen type, frequency ordered, methodology or types of components to aid in the diagnosis/treatment of disease.
Palmetto considers the performance of multiple molecular biomarkers, regardless of whether the test requisition lists the tests as a panel or individually, and completed on a single sample to be a 'panel' of tests. Therefore, each panel should be registered and billed with a single CPT code and a unique MolDX identifier. Based on data analysis of MolDX claims, labs are submitting multiple biomarker 'panels' as individual tests similar to the submission of the previous stacking codes.
Example: A lab receives a patient specimen and performs the following tests:
  • CPT code 81225-CYP2C19, cv
  • CPT code 81240-F2, 20210G>A
  • CPT code 81241-F5, Leiden
The panel of three tests listed above should be registered and claims submitted with CPT code 81479 and a single MolDX ID. If the lab also performs one of the three panel’s biomarkers on patient specimens, each biomarker must also be registered and receive a unique ID to submit on claims when only that biomarker is performed. Again, a single CPT code should be billed with a unique ID.
To correct this example, the lab must register four tests and receive identifiers for MolDX claim submission:
Test #
Test Name
Biomarkers
ID
CPT Code
1
Clotting Test Panel
CYP2C19, cv
F2, 20210G>A
F5, Leiden
Z1234
81479
2
CYP2C19
CYP2C19, cv
Z5678
81225
3
F2, 20210G>A
F2, 20210G>A
ZA234
81240
4
F5, Leiden
F5, Leiden
ZA567
81241
Labs should register all panels and obtain a unique MolDX identifier for each panel. If a lab does NOT perform single biomarker tests, they must notify the registry of this registration error.


Updated 12 31 2015.

Brook Byers 2019 Speech at Stanford

For blog and link to YouTube, here:
http://www.discoveriesinhealthpolicy.com/2019/10/noted-life-sciences-investor-brook.html


Cloud transcript here.


Monday, October 14, 2019

MolDx LCD Release Time Watch

As of October 14, 2019, Palmetto MOLDX has 13 LCDs in comment period (which runs to Novemer 15, 2019).

From its May 2019 LCDs, Palmetto has 7 LCDs still in review and not released to final, after a comment period that closed June 20, 2019.   This is 116 days, or 3.9 months.

An 8th LCD, L38039, TruGraf renal rejection test, was released to final on October 4, 2019, which was 106 days or 3.5 months after its June 20 close-comments date.

Note that MolDx probably does not finalize LCDs until all comments are in, in all MoLDx MACs.   This could have been a few weeks later than June 20 for the various MACs (Noridian, CGS, WPS).

I've put a very simple Excel in the cloud here.


50 Slide Deck from NHGRI 2016: The Methods for NGS

Mardis of Wash Univ/McDonnell Center presented a 53-slide deck at NHGRI in 2016 on the various main methods for WGS - Illumina, Thermo Fisher, Pac Bio, etc., and key considerations.   Online here:

https://www.genome.gov/sites/default/files/media/files/2019-03/Next-Generation%20Sequencing%20Technologies_052516.pdf