Sunday, March 20, 2016

California Final Lung LCD Eff. April 2016 L36198

https://www.cms.gov/medicare-coverage-database/details/lcd-details.aspx?LCDId=36198&ContrId=345

Note: Released with almost no changes, e.g. =15 years changes to =< 15 years.


LCD ID
L36198

Original ICD-9 LCD ID
N/A

LCD Title
MolDX- CDD: NSCLC, Comprehensive Genomic Profile Testing

AMA CPT / ADA CDT / AHA NUBC Copyright Statement
CPT only copyright 2002-2015 American Medical Association. All Rights Reserved. CPT is a registered trademark of the American Medical Association. Applicable FARS/DFARS Apply to Government Use. Fee schedules, relative value units, conversion factors and/or related components are not assigned by the AMA, are not part of CPT, and the AMA is not recommending their use. The AMA does not directly or indirectly practice medicine or dispense medical services. The AMA assumes no liability for data contained or not contained herein.

The Code on Dental Procedures and Nomenclature (Code) is published in Current Dental Terminology (CDT). Copyright © American Dental Association. All rights reserved. CDT and CDT-2010 are trademarks of the American Dental Association.

UB-04 Manual. OFFICIAL UB-04 DATA SPECIFICATIONS MANUAL, 2014, is copyrighted by American Hospital Association (“AHA”), Chicago, Illinois. No portion of OFFICIAL UB-04 MANUAL may be reproduced, sorted in a retrieval system, or transmitted, in any form or by any means, electronic, mechanical, photocopying, recording or otherwise, without prior express, written consent of AHA.” Health Forum reserves the right to change the copyright notice from time to time upon written notice to Company. 

Original Effective Date
For services performed on or after 04/15/2016
Revision Effective Date
N/A

Revision Ending Date
N/A
Retirement Date
N/A
Notice Period Start Date
02/25/2016

Notice Period End Date
04/14/2016
CMS National Coverage Policy
Title XVIII of the Social Security Act, §1862(a)(1)(A)allows coverage and payment for only those services that are considered to be reasonable and necessary for the diagnosis or treatment of illness or injury or to improve the functioning of a malformed body member

Title XVIII of the Social Security Act, §1862(a)(1)(D) items and services related to research and experimentation

Title XVIII of the Social Security Act, §1833(e), prohibits Medicare payment for any claim which lack the necessary information to process the claim.

42 CFR 410.32(a) Diagnostic x-ray tests, diagnostic laboratory tests, and other diagnostic tests: Conditions

42CFR411.15(k)(1) Particular services excluded from coverage

CMS On-Line Manual, Publication 100-08, Medicare Program Integrity Manual, Chapter 3, §3.4.1.3, diagnosis code requirements
Coverage Guidance
Coverage Indications, Limitations, and/or Medical Necessity

This policy provides limited coverage for comprehensive somatic genomic profiling on tumor tissue-only (hereafter called CGP) for patients with metastatic non-small cell lung cancer (NSCLC) who are lifetime non-smokers (also known as never-smokers) or former light smokers (≤ 15 pack year history) and who tested negative for epidermal growth factor receptor (EGFR) mutations, EML4-ALK rearrangements, and ROS1 rearrangements when initial testing was done by an FDA-approved companion diagnostic (CDx) or by a laboratory developed test (LDT) for these genomic alterations. Alterations detected by CGP, if positive, may allow individuals to be treated with a targeted therapy for which they were previously ineligible. At the current time, CGP for germline (i.e. inheritable) mutations is not a Medicare benefit.

Background

It is estimated that more than 220,000 new cases of lung cancer will be diagnosed in the United States (US) this year. This represents roughly 13% of all new cancer diagnoses, and 27% of cancer deaths. Sadly, the estimated 5-year survival rate for all lung cancer patients is 17%, and only 4% for patients with metastatic disease.

The pathophysiological development of lung cancer is complicated, with several known genomic alterations found individually or in combination in many patients. These alterations may be due to toxic exposure or underlying genetic factors, and not all alterations have the same impact on disease development or prognosis. Some alterations appear to be integral to the transformation and ongoing growth of the tumor (driver mutations). Among the best studied in this class are point alterations and indels in EGFR and EML4-ALK translocations. EGFR mutated NSCLC is found in up to 15% of all lung cancers in the US. These mutations convey a more favorable prognosis and allow treatment with oral EGFR inhibitors such as erlotinib, gefitinib, or afatinib. Similarly, translocations of ALK and EML4 or other less common fusion partners occur in approximately 4% of all NSCLC patients and permit treatment with oral ALK-targeted inhibitors such as crizotinib and ceritinib.

The majority of NSCLC cases are diagnosed in patients with a smoking history. Lifetime non-smokers or light former smokers (≤ 15 pack years) have different disease compared to their heavier smoking counterparts. Sequencing of tumor specimens in never-smokers has shown a higher mutation frequency of EGFR than smokers, with some non-smoking ethnic groups such as Asian women having a much higher mutation frequency than their Caucasian counterparts. Similar results have been shown with ALK translocations. For example, in one study involving never-smokers or light smokers with adenocarcinoma of the lung, 22% of patients’ tumors harbored an ALK. When EGFR mutation carriers were excluded, 33% of patients had an ALK translocation. While ALK translocations and EGFR mutations certainly occur at a meaningful frequency in former smokers with more significant history of cigarette use, use of the enrichment approach described herein may allow a more efficient completion of this initial phase of study.

Currently, a variety of different techniques are used to test for these genomic alterations in tumor specimens including three FDA cleared/approved CDx tests for NSCLC to determine if a patient is a candidate for targeted therapy. For EGFR, there is the Cobas® EGFR Mutation Test for erlotinib and Therascreen EGFR RCQ PCR Kit for afatinib. For ALK, there is the Vysis ALK Break Apart FISH Probe Kit for crizotinib. These tests look at specific regions in the target gene to determine if the genomic alteration of interest is present.

In addition to these FDA-approved CDx test, there are a variety of laboratory-developed tests (LDTs) that are used to identify EGFR mutations and ALK translocations. These include bidirectional Sanger sequencing, direct DNA sequencing, hybridization sequencing, pyrosequencing and sequencing by denaturation to name a few. Some of these LDTs provide more extensive genetic analysis than their FDA-approved counterparts, but there are few head-to-head comparison studies demonstrating greater diagnostic accuracy or clinical utility of the various approaches.

For various reasons, CDx or LDT sequencing techniques may miss deleterious EGFR mutations and ALK translocations. For example, alterations may occur outside the sequenced region or involve complex alterations (e.g. insertions or deletions (indels), copy number alterations, or translocations) that are not detectable by the specific test. Newer techniques such as massively parallel sequencing, also known as next generation sequencing (NGS), offer the possibility of not only increased analytical sensitivity but also the ability to detect a broader range of genomic alterations than existing CDx and LDT techniques.

In a recent study by Drilon, lifetime non-smokers or light smokers who tested negative for alterations in various target genes (including EGFR and ALK) in a broad “focused panel of a variety of non-NGS” tests developed at a major academic institution were studied using a specific type of NGS, namely CGP. Despite robust non-NGS (and CGP) testing using multiple techniques, CGP testing identified EGFR mutations in 7% more patients than had been identified by prior combined methodologies, and 6% more ALK translocations than by previous FISH analysis. Although some of the EGFR mutated malignancies found by NGS are less likely to respond to available EGFR tyrosine kinase inhibitors (TKIs) (e.g. exon 20 insertions), others such as complex double mutations and exon 18 mutations (which are typically undetectable with so-called “hotspot” panels), are likely to benefit from targeted therapy. CGP analysis was equally compelling for ALK translocations. In two patients, where FISH analysis was clearly negative, translocations were identified using CGP. These patients would likely benefit from treatment with crizotinib.

Although the study population is small, the significant number of potentially actionable genomic alterations that were missed by non-NGS methodologies is compelling, and demonstrates that CGP can identify a group of non- small cell lung cancer patients who are likely to benefit from targeted therapy.

Comprehensive Genomic Profiling (CGP) Test Description:

CGP analysis is defined as a single test using tumor tissue only (i.e., not matched tumor and normal) that does not distinguish between somatic and germline alterations and can detect the following classes of alterations:
  1. Base pair substitutions (including single nucleotide variants (SNVs))

  2. Insertions and deletions (Indels; up to 70 bp)

  3. Copy number variations (CNVs; including both amplifications (ploidy < 4 with copy number = 8) and homozygous deletions (ploidy < 4 with copy number = 0)

  4. Translocations

Other non-NGS testing platforms may be considered if they can similarly detect all four classes of alterations with comparable test performance as CGP.

MolDX CGP Analysis Coverage

CGP analysis is covered only when the following conditions are met:
  • Patient has been diagnosed with advanced (Stage IIIB or IV) NSCLC; and

  • Patient is a lifetime non-smoker or former light smoker with ≤ 15 pack year history of smoking; and

  • Patient previously tested negative for EGFR mutations, ALK rearrangements, and ROS1 rearrangements through non-CGP methods; and

  • Testing is performed by a lab that satisfies the CMS MolDX Contractor's published AV criteria.


Noridian expects participating laboratories to:
  • Prior to CGP testing, verify that each patient has previously tested negative for EGFR mutations, ALK
    rearrangements, and ROS1 rearrangements

  • Report the following to Palmetto GBA dba the CMS MolDX contractor every six months on an individual patient basis but de-identified (i.e., no protected health information):

    • Patient demographics including patient age when the specimen was collected, and gender;

    • Sample information including whether CGP testing was performed on the same specimen DNA as the original test result, a re-biopsy from the same tumor site, or a re-biopsy from a different tumor site, and the dates of biopsy for the original non-CGP and CGP tests;

    • Non-CGP test methodology resulting in a negative EGFR mutations, or ALK or ROS1 rearrangements;

    • Alterations in the following genes: ALK, BRAF, EGFR, HER2, KRAS, MET, ROS1, and RET.

    • Any treatment received after CGP testing, the current response status and duration of response

  • Reports will be delivered every 6 months in a mutually acceptable format.


Future stamp
Bill Type Codes:
Contractors may specify Bill Types to help providers identify those Bill Types typically used to report this service. Absence of a Bill Type does not guarantee that the policy does not apply to that Bill Type. Complete absence of all Bill Types indicates that coverage is not influenced by Bill Type and the policy should be assumed to apply equally to all claims.
013xHospital Outpatient
Revenue Codes:
Contractors may specify Revenue Codes to help providers identify those Revenue Codes typically used to report this service. In most instances Revenue Codes are purely advisory. Unless specified in the policy, services reported under other Revenue Codes are equally subject to this coverage determination. Complete absence of all Revenue Codes indicates that coverage is not influenced by Revenue Code and the policy should be assumed to apply equally to all Revenue Codes.

N/A
CPT/HCPCS Codes

Group 1 Paragraph: N/A

Group 1 Codes:
81445TARGETED GENOMIC SEQUENCE ANALYSIS PANEL, SOLID ORGAN NEOPLASM, DNA ANALYSIS, AND RNA ANALYSIS WHEN PERFORMED, 5-50 GENES (EG, ALK, BRAF, CDKN2A, EGFR, ERBB2, KIT, KRAS, NRAS, MET, PDGFRA, PDGFRB, PGR, PIK3CA, PTEN, RET), INTERROGATION FOR SEQUENCE VARIANTS AND COPY NUMBER VARIANTS OR REARRANGEMENTS, IF PERFORMED
81455TARGETED GENOMIC SEQUENCE ANALYSIS PANEL, SOLID ORGAN OR HEMATOLYMPHOID NEOPLASM, DNA ANALYSIS, AND RNA ANALYSIS WHEN PERFORMED, 51 OR GREATER GENES (EG, ALK, BRAF, CDKN2A, CEBPA, DNMT3A, EGFR, ERBB2, EZH2, FLT3, IDH1, IDH2, JAK2, KIT, KRAS, MLL, NPM1, NRAS, MET, NOTCH1, PDGFRA, PDGFRB, PGR, PIK3CA, PTEN, RET), INTERROGATION FOR SEQUENCE VARIANTS AND COPY NUMBER VARIANTS OR REARRANGEMENTS, IF PERFORMED
81479UNLISTED MOLECULAR PATHOLOGY PROCEDURE




ICD-10 Codes that Support Medical Necessity

Group 1 Paragraph: N/A

Group 1 Codes:
Search By:

Group 1Codes

ICD-10 CODEDESCRIPTION
C33Malignant neoplasm of trachea
C34.00Malignant neoplasm of unspecified main bronchus
C34.01Malignant neoplasm of right main bronchus
C34.02Malignant neoplasm of left main bronchus
C34.10Malignant neoplasm of upper lobe, unspecified bronchus or lung
C34.11Malignant neoplasm of upper lobe, right bronchus or lung
C34.12Malignant neoplasm of upper lobe, left bronchus or lung
C34.2Malignant neoplasm of middle lobe, bronchus or lung
C34.30Malignant neoplasm of lower lobe, unspecified bronchus or lung
C34.31Malignant neoplasm of lower lobe, right bronchus or lung
C34.32Malignant neoplasm of lower lobe, left bronchus or lung
C34.80Malignant neoplasm of overlapping sites of unspecified bronchus and lung
C34.81Malignant neoplasm of overlapping sites of right bronchus and lung
C34.82Malignant neoplasm of overlapping sites of left bronchus and lung
C34.90Malignant neoplasm of unspecified part of unspecified bronchus or lung
C34.91Malignant neoplasm of unspecified part of right bronchus or lung
C34.92Malignant neoplasm of unspecified part of left bronchus or lung

California Q&A on Lung LCD (February 2016)

https://med.noridianmedicare.com/web/jfb/policies/lcd/draft/moldx-cdd-nsclc-comprehensive-genomic-profile-testing-comments-and-responses


MolDX - CDD: NSCLC, Comprehensive Genomic Profile Testing Comments and Responses

Comment 1: 
  • Scientific literature demonstrates actionable drivers that may be identified by multiplex/NGS are common in smokers; since finding a target mutation radically alters the treatment for patients, strong consideration should be given to broader coverage;
  • Alteration in different genes by CGP may inform physicians about clinical trial or off-label options that may benefit patients;
  • Since coverage applies only to never- and light-smokers with metastatic disease, under 24% of 26,000 diagnosed NSCLC patients with negative EGFR and/or ELK mutations are eligible for CGP NGS, especially when the rest of lung cancer patients stand to benefit by the application of comprehensive genomic profiling;
  • Allow coverage of other testing platforms if the detect the same classes of alterations with comparable performance as in the policy
Response 1:  Although mutations are common in both smokers and never-smokers, actionable mutations such as EGFR mutations, ALK rearrangements, and ROS1 rearrangements occur at a much lower frequency in smokers than in never- or light-smokers. The probability of finding an undiscovered mutation in smokers given its recorded frequency, and the probability that a mutation will be identified by CGP, is estimated to be less than 1 in 400. This would dilute the potential for this approach to replace alternative testing as the first step.  Furthermore, it has been shown that heavy smokers do not have the same response to EGFR inhibitors in terms of progression free survival (PFS)*. Never- or light-smokers with metastatic disease are a logical first step for coverage because CGP testing has the highest impact on care in the patients who are most likely to have actionable mutations.  This is the premise of the Drilon paper; it is the cornerstone of this policy.
Moreover, this is not a policy about NGS testing.  Rather, this policy is about a specific type of NGS-based testing (i.e., tissue-only somatic comprehensive genomic panels) in patients who are at higher risk of having mutations, despite exhaustive LDT testing that has failed to identify any mutation, and requires the collection of outcome data to inform future patient management decisions.  Although mutations were found by CGP in patients (Drilon), it is unclear that they will respond to treatment.  Thus, CDD in a specific population (never- and light-smokers) allows "proof of concept" before Medicare coverage can be justified for larger patient populations.
*Kim MH, Kim HR, Cho BC, et al. Impact of cigarette smoking on response to epidermal growth factor receptor (EGFR)-tyrosine kinase inhibitors in lung adenocarcinoma with activating EGFR mutations.  Lung Cancer 2014;84 (2):196-202. doi: 10.1016/j.lungcan.2014.01.022. Epub 2014 Feb 3.
Comment 2:  Expand genes in NGS panel
  • Request clarification to assist in triaging patients for such testing;
  • While targeted exon sequencing using a massive parallel sequencing (MPS) platform is not comprehensive genomic profiling, a commenter notes that the MPS to assess EGFR, KRAS and BRAF has identified 8% more mutations than real-time PCR previously used.  By combining MPS on more than one cancer type, they have constructed a single panel with cost and time-savings, as well as tissue savings compared to serial gene testing; request clarification that a small, targeted panel using MPS is an appropriate first-line test.
Response 2:  In addition to SNVs and/or indels in EGFR and KRAS, and rearrangements in ALK, recent NCCN guidelines for NSCLC (v5.2015) indicate that the following alterations have "emerging targeted agents": ROS1 rearrangements, BRAF V600E mutation, MET amplification, HER2 mutations, and RET rearrangements.  The policy will be expanded to include data collection for these additional genes.
Medicare is not specifying technologies or platforms for first-line testing.  This policy specifies that CGP will be covered to identify a small group of patients who have already tested negative for EGFR mutations, ALK rearrangements and ROS1 rearrangements
Comment 3: Need NGS upfront due to tissue availability; also Circulating Tumor DNA (ctDNA) testing; Sequential testing algorithm may harm patients by delaying therapy and exhausting tissue samples - A commenter notes that "As many as 25% of NSCLC patients do not have adequate tissue material for molecular testing. The commenter has developed a nine gene ctDNA test, including alterations in EGFR and ALK for use in these patients that it intends to launch later in 2015. The way this LCD is currently worded patients who lack adequate tissue for EGFR and ALK testing would not be eligible for CGP testing even though this would be possible using these new approaches. In addition, the characteristics of ctDNA testing will be different than tissue based NGS testing.  Because ctDNA levels vary greatly in patients and some patients do not release appreciable amounts of ctDNA, ctDNA testing will not be as sensitive as tissue testing. Additionally, although the critical factors defining ctDNA testing performance are still similar to tissue testing the detectable MAF (or ctDNA level) is much lower with a high-quality ctDNA test.  In our view these MAFs for ctDNA should be between 0.01% and 0.05% for mutations and >0.1 % for translocations. It also should be noted that copy number amplifications while detectable in ctDNA are typically only detectable at MAFs of 1%-2% unless an extremely sequence intensive technique is used (this enables detection down to levels of >0.1%), and recommends that The MolDX Contractor specify that this guidance is specific for tissue-based CGP testing and would not apply when the patient has inadequate material for CGP testing.
Response 3:  Noridian recognizes that availability of tissue is very important.  However, this is a limited coverage policy with specific data development expectations for coverage (CDD) focusing on a specific sub-group of patients who have already been tested and found to be negative by other technologies AND have tissue available for testing.  As stated above, this policy is NOT about NGS testing more generally. The premise of the Drilon paper is that never- and light-smokers have a higher likelihood of having less complex driver mutations than their smoking counterparts.  This premise is well founded with some patients having mutations that were missed by an LDT done at the institution.  However, short-comings of the study were: its small size, predominance of never smokers, potential patient selection bias due to the ability to re-biopsy, and limited follow-up on treatment outcomes.  In addition, because there was no direct comparison to an FDA-approved companion diagnostic, we cannot directly extrapolate from the results of testing to improved outcomes, thus the need to collect data.    Because the outcomes of these patients are still unknown, we must follow the inclusion criteria that were used in the study, thus the limitation to never- and light-smokers.  Similarly, since CGP testing was limited to patients who previously tested negative for EGFR mutations, ALK rearrangements and ROS1 rearrangements, the policy is based on the same testing schema.  Noridian expects that as outcomes data are collected and analyzed, CGP may become first-line testing, and then the issue of specimen availability will be moot. At the current time, CGP is limited to patients with available tissue for testing and does not apply to ctDNA testing, so the policy will remain unchanged. 
Comment 4:  Limit of Detection:  In the proposed LCD, The MolDX Contractor indicates that the studies cited demonstrate test performance of 95%-99% sensitivity across the four alteration classes and >99% positive predictive value (PPV). However, this mention omits the fact that sequence mutation sensitivity and PPV were demonstrated at mutant allele fraction (MAF) levels as low as 5%. MAF is a critical parameter in measuring test performance for the analysis of sequence mutations. It is orders of magnitude easier to have >99% PPV at 50% MAF than at 5% MAF. In addition, a large fraction of mutations occur at lower MAF ranges in the average sample (54% are <20% and 26% are <10%). A test that does not demonstrate these performance characteristics at low MAFs will be significantly inferior to tests that do and miss many mutations that may otherwise be clinically actionable. The commenter recommends that The MolDX Contractor specify that sensitivity and specificity metrics must be achieved at MAFs as low as 5% in order to be considered for coverage.
Response 4:  We agree and have published the MolDX analytical requirements, linked in the policy.  In addition, we note that the clinical significance of mutations detected at very low allele frequencies in adequate biopsy specimens is (to our knowledge) currently unknown.
Comment 5: Differentiating between Somatic and Germ-line mutations - A commenter notes that many CGP tests do not utilize matched patient normal D|NA. The commenter believes the lack of patient normal sample results in sub-optimal result quality because there is no way to be sure that the identified mutations are somatic (tumor-specific) in nature without analysis of the matched normal DNA from the same patient.  They note that "taking action on these mutations not only deprives the patient of the opportunity to receive another more efficacious treatment option but also may do harm to the patient. Note that tests that accurately distinguish between somatic and germline mutations do not need to report any germline mutations."  The commenter recommends that The MolDX Contractor reword the first sentence of the CGP test description to define CGP testing as "testing that accurately distinguishes between somatic and germline mutations."
Response 5:  The LCD has been revised to clarify that it applies to tumor tissue-only testing and somatic-only reporting. 
Comment 6:  The MolDX Contractor asks that reports be submitted according to HIPAA standards; Urge lab reporting requirement to include all actionable mutations
Response 6:  Noridian expects patient line-item specific information and to include all actionable mutations. The policy has been revised accordingly.
Comment 7:  What specific billing code applies? 
Response 7:  An LCD can only contain "reasonable and necessary" criteria.  Coding and billing guidelines will be attached to the final document accordingly to Medicare guidelines.
Comment 8:  Mulitplex/NGS Testing is no longer experimental.
Response 8:  While the testing may not be experimental, the multitude of genes tested does not meet the criteria of "reasonable and necessary". 
Comment 9: Lab Verification by MolDX:  Two commenters strongly disagree with the lab verification requirements imposed under MolDX and assert that CMS is the authority to regulate analytical validity (AV) pursuant to CLIA
Response 9:  CLIA certifies a laboratory and provides an assurance that the lab has Standard Operating Procedures, a Quality Control program, proficiency testing, qualified personnel, etc.  MolDX has the responsibility to assure the public that a given test has been adequately validated (i.e., is safe and effective) as part of the criteria to meet "reasonable and necessary". 
Comment 10: Clinical Outcomes Reporting Requirement:  the proposal outlined by The MolDX Contractor is scientifically, financially, and ethically not feasible for laboratories
Response 10:  We recognize the additional work required of laboratories due to the reporting requirements and have therefore made the reporting requirements as parsimonious as possible to allow the scientific and clinical communities to draw some meaningful conclusions or at least provide some data to support generating testable hypotheses. Most of the genes and variant types that are currently being tested on NGS panels do not have sufficient evidence to be "reasonable and necessary" under Medicare guidelines, hence the reporting requirements in an effort to accelerate our understanding of the clinical utility of testing for alterations in these genes. Such information will benefit all stakeholders, most especially patients and providers.  We believe our reporting requirements have been calibrated appropriately to balance the outcome expectations with the effort required. In addition, it is imperative to document that when comprehensive NGS analysis identifies actionable mutations missed by other methodologies, whether they are FDA-approved companion diagnostics or LDTs, the clinical outcomes are similar.
Comment 11: Support policy as written:  Multiple comments supportive of the policy. 
Response 11: NA
Comment 12:  A commenter requests information regarding how to find the MolDX contractor's published AV criteria and how to send information to the MolDX contractor. 
Response 12:  The MolDX program and contact information can be obtained via:  www.palmettogba.com/moldx This link will take you to an external website..
Last Updated Feb 25, 2016


California Draft LCD for Lung Cancer Profiling DL36198

https://www.cms.gov/medicare-coverage-database/details/lcd-details.aspx?LCDId=36197&ContrId=345


PROPOSED/DRAFT Local Coverage Determination (LCD): 
MolDX: NSCLC, Comprehensive Genomic Profile Testing (DL36198)

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Proposed/Draft stamp
Please note: This is a Proposed/Draft policy.
Proposed/Draft LCDs are works in progress that are available on the Medicare Coverage Database site for public review. Proposed/Draft LCDs are not necessarily a reflection of the current policies or practices of the contractor.
CONTRACTOR NAMECONTRACT TYPECONTRACT NUMBERJURISDICTIONSTATE(S)
Noridian Healthcare Solutions, LLCA and B MAC02102 - MAC BJ - FAlaska
Noridian Healthcare Solutions, LLCA and B MAC02202 - MAC BJ - FIdaho
Noridian Healthcare Solutions, LLCA and B MAC02302 - MAC BJ - FOregon
Noridian Healthcare Solutions, LLCA and B MAC02402 - MAC BJ - FWashington
Noridian Healthcare Solutions, LLCA and B MAC03102 - MAC BJ - FArizona
Noridian Healthcare Solutions, LLCA and B MAC03202 - MAC BJ - FMontana
Noridian Healthcare Solutions, LLCA and B MAC03302 - MAC BJ - FNorth Dakota
Noridian Healthcare Solutions, LLCA and B MAC03402 - MAC BJ - FSouth Dakota
Noridian Healthcare Solutions, LLCA and B MAC03502 - MAC BJ - FUtah
Noridian Healthcare Solutions, LLCA and B MAC03602 - MAC BJ - FWyoming

Document Information

Proposed/Draft stamp
Source LCD ID
L36198
Proposed LCD ID
DL36198

Original ICD-9 LCD ID
N/A

Proposed LCD Title
MolDX: NSCLC, Comprehensive Genomic Profile Testing

AMA CPT / ADA CDT / AHA NUBC Copyright Statement
CPT only copyright 2002-2015 American Medical Association. All Rights Reserved. CPT is a registered trademark of the American Medical Association. Applicable FARS/DFARS Apply to Government Use. Fee schedules, relative value units, conversion factors and/or related components are not assigned by the AMA, are not part of CPT, and the AMA is not recommending their use. The AMA does not directly or indirectly practice medicine or dispense medical services. The AMA assumes no liability for data contained or not contained herein.

The Code on Dental Procedures and Nomenclature (Code) is published in Current Dental Terminology (CDT). Copyright © American Dental Association. All rights reserved. CDT and CDT-2010 are trademarks of the American Dental Association.

UB-04 Manual. OFFICIAL UB-04 DATA SPECIFICATIONS MANUAL, 2014, is copyrighted by American Hospital Association (“AHA”), Chicago, Illinois. No portion of OFFICIAL UB-04 MANUAL may be reproduced, sorted in a retrieval system, or transmitted, in any form or by any means, electronic, mechanical, photocopying, recording or otherwise, without prior express, written consent of AHA.” Health Forum reserves the right to change the copyright notice from time to time upon written notice to Company. 


CMS National Coverage Policy
Title XVIII of the Social Security Act, §1862(a)(1)(A)allows coverage and payment for only those services that are considered to be reasonable and necessary for the diagnosis or treatment of illness or injury or to improve the functioning of a malformed body member

Title XVIII of the Social Security Act, §1862(a)(1)(D) items and services related to research and experimentation

Title XVIII of the Social Security Act, §1833(e), prohibits Medicare payment for any claim which lack the necessary information to process the claim.

42 CFR 410.32(a) Diagnostic x-ray tests, diagnostic laboratory tests, and other diagnostic tests: Conditions

42CFR411.15(k)(1) Particular services excluded from coverage

CMS On-Line Manual, Publication 100-08, Medicare Program Integrity Manual, Chapter 3, §3.4.1.3, diagnosis code requirements
Coverage Guidance
Coverage Indications, Limitations, and/or Medical Necessity

This policy provides limited coverage for comprehensive somatic genomic profiling on tumor tissue-only (hereafter called CGP) for patients with metastatic non-small cell lung cancer (NSCLC) who are lifetime non-smokers (also known as never-smokers) or former light smokers (=15 pack year history) and who tested negative for epidermal growth factor receptor (EGFR) mutations, EML4-ALK rearrangements, and ROS1 rearrangements when initial testing was done by an FDA-approved companion diagnostic (CDx) or by a laboratory developed test (LDT) for these genomic alterations. Alterations detected by CGP, if positive, may allow individuals to be treated with a targeted therapy for which they were previously ineligible. At the current time, CGP for germline (i.e. inheritable) mutations is not a Medicare benefit.

Background

It is estimated that more than 220,000 new cases of lung cancer will be diagnosed in the United States (US) this year. This represents roughly 13% of all new cancer diagnoses, and 27% of cancer deaths. Sadly, the estimated 5-year survival rate for all lung cancer patients is 17%, and only 4% for patients with metastatic disease.

The pathophysiological development of lung cancer is complicated, with several known genomic alterations found individually or in combination in many patients. These alterations may be due to toxic exposure or underlying genetic factors, and not all alterations have the same impact on disease development or prognosis. Some alterations appear to be integral to the transformation and ongoing growth of the tumor (driver mutations). Among the best studied in this class are point alterations and indels in EGFR and EML4-ALK translocations. EGFR mutated NSCLC is found in up to 15% of all lung cancers in the US. These mutations convey a more favorable prognosis and allow treatment with oral EGFR inhibitors such as erlotinib, gefitinib, or afatinib. Similarly, translocations of ALK and EML4 or other less common fusion partners occur in approximately 4% of all NSCLC patients and permit treatment with oral ALK-targeted inhibitors such as crizotinib and ceritinib.

The majority of NSCLC cases are diagnosed in patients with a smoking history. Lifetime non-smokers or light former smokers (=15 pack years) have different disease compared to their heavier smoking counterparts. Sequencing of tumor specimens in never-smokers has shown a higher mutation frequency of EGFR than smokers, with some non-smoking ethnic groups such as Asian women having a much higher mutation frequency than their Caucasian counterparts. Similar results have been shown with ALK translocations. For example, in one study involving never-smokers or light smokers with adenocarcinoma of the lung, 22% of patients’ tumors harbored an ALK. When EGFR mutation carriers were excluded, 33% of patients had an ALK translocation. While ALK translocations and EGFR mutations certainly occur at a meaningful frequency in former smokers with more significant history of cigarette use, use of the enrichment approach described herein may allow a more efficient completion of this initial phase of study.

Currently, a variety of different techniques are used to test for these genomic alterations in tumor specimens including three FDA cleared/approved CDx tests for NSCLC to determine if a patient is a candidate for targeted therapy. For EGFR, there is the Cobas® EGFR Mutation Test for erlotinib and Therascreen EGFR RCQ PCR Kit for afatinib. For ALK, there is the Vysis ALK Break Apart FISH Probe Kit for crizotinib. These tests look at specific regions in the target gene to determine if the genomic alteration of interest is present.

In addition to these FDA-approved CDx test, there are a variety of laboratory-developed tests (LDTs) that are used to identify EGFR mutations and ALK translocations. These include bidirectional Sanger sequencing, direct DNA sequencing, hybridization sequencing, pyrosequencing and sequencing by denaturation to name a few. Some of these LDTs provide more extensive genetic analysis than their FDA-approved counterparts, but there are few head-to-head comparison studies demonstrating greater diagnostic accuracy or clinical utility of the various approaches.

For various reasons, CDx or LDT sequencing techniques may miss deleterious EGFR mutations and ALK translocations. For example, alterations may occur outside the sequenced region or involve complex alterations (e.g. insertions or deletions (indels), copy number alterations, or translocations) that are not detectable by the specific test. Newer techniques such as massively parallel sequencing, also known as next generation sequencing (NGS), offer the possibility of not only increased analytical sensitivity but also the ability to detect a broader range of genomic alterations than existing CDx and LDT techniques.

In a recent study by Drilon, lifetime non-smokers or light smokers who tested negative for alterations in various target genes (including EGFR and ALK) in a broad “focused panel of a variety of non-NGS” tests developed at a major academic institution were studied using a specific type of NGS, namely CGP. Despite robust non-NGS (and CGP) testing using multiple techniques, CGP testing identified EGFR mutations in 7% more patients than had been identified by prior combined methodologies, and 6% more ALK translocations than by previous FISH analysis. Although some of the EGFR mutated malignancies found by NGS are less likely to respond to available EGFR tyrosine kinase inhibitors (TKIs) (e.g. exon 20 insertions), others such as complex double mutations and exon 18 mutations (which are typically undetectable with so-called “hotspot” panels), are likely to benefit from targeted therapy. CGP analysis was equally compelling for ALK translocations. In two patients, where FISH analysis was clearly negative, translocations were identified using CGP. These patients would likely benefit from treatment with crizotinib.

Although the study population is small, the significant number of potentially actionable genomic alterations that were missed by non-NGS methodologies is compelling, and demonstrates that CGP can identify a group of non- small cell lung cancer patients who are likely to benefit from targeted therapy.

Comprehensive Genomic Profiling (CGP) Test Description:

CGP analysis is defined as a single test using tumor tissue only (i.e., not matched tumor and normal) that does not distinguish between somatic and germline alterations and can detect the following classes of alterations:
  1. Base pair substitutions (including single nucleotide variants (SNVs))

  2. Insertions and deletions (Indels; up to 70 bp)

  3. Copy number variations (CNVs; including both amplifications (ploidy < 4 with copy number = 8) and homozygous deletions (ploidy < 4 with copy number = 0)

  4. Translocations

Other non-NGS testing platforms may be considered if they can similarly detect all four classes of alterations with comparable test performance as CGP.

MolDX CGP Analysis Coverage

CGP analysis is covered only when the following conditions are met:
  • Patient has been diagnosed with advanced (Stage IIIB or IV) NSCLC; and

  • Patient is a lifetime non-smoker or former light smoker with =15 pack year history of smoking; and

  • Patient previously tested negative for EGFR mutations, ALK rearrangements, and ROS1 rearrangements through non-CGP methods; and

  • Testing is performed by a lab that satisfies the MolDX Contractor's published AV criteria.


Noridian expects participating laboratories to:
  • Prior to CGP testing, verify that each patient has previously tested negative for EGFR mutations, ALK
    rearrangements, and ROS1 rearrangements

  • Report the following to MolDX every six months on an individual patient basis but de-identified (i.e., no protected health information):

    • Patient demographics including patient age when the specimen was collected, and gender;

    • Sample information including whether CGP testing was performed on the same specimen DNA as the original test result, a re-biopsy from the same tumor site, or a re-biopsy from a different tumor site, and the dates of biopsy for the original non-CGP and CGP tests;

    • Non-CGP test methodology resulting in a negative EGFR mutations, or ALK or ROS1 rearrangements;

    • Alterations in the following genes: ALK, BRAF, EGFR, HER2, KRAS, MET, ROS1, and RET.

    • Any treatment received after CGP testing, the current response status and duration of response

  • Reports will be delivered every 6 months in a mutually acceptable format.


Synopsis of Changes
CHANGESFIELDS CHANGED
N/AN/A
Associated Information
N/A
Sources of Information and Basis for Decision
Please refer to the attachment titled, "References" found at the bottom of this LCD.
Open Meetings/Part B MAC Contractor Advisory Committee (CAC) Meetings
MEETING DATEMEETING TYPEMEETING STATE(S)MEETING INFORMATION
06/04/2015Open Meeting
  • Alaska
  • Arizona
  • Idaho
  • Montana
  • North Dakota
  • Oregon
  • South Dakota
  • Utah
  • Washington
  • Wyoming
Noridian Headquarters – Room W3 900 42nd St S Fargo, ND 58103
Comment Period Start Date
06/04/2015
Comment Period End Date
08/10/2015
Released to Final LCD Date
02/03/2016
Reason for Proposed LCD
  • Creation of Uniform LCDs With Other MAC Jurisdiction
Proposed Contact
Noridian Healthcare Solutions, LLC JF Part B Contractor Medical Director(s) 
Policy Development - Medicare Part B - Drafts
900 42nd Street S., PO Box 6704
Fargo, ND 58108 
policyb.drafts@noridian.com
Proposed/Draft stamp
Bill Type Codes:
Contractors may specify Bill Types to help providers identify those Bill Types typically used to report this service. Absence of a Bill Type does not guarantee that the policy does not apply to that Bill Type. Complete absence of all Bill Types indicates that coverage is not influenced by Bill Type and the policy should be assumed to apply equally to all claims.
013xHospital Outpatient
014xHospital - Laboratory Services Provided to Non-patients
Revenue Codes:
Contractors may specify Revenue Codes to help providers identify those Revenue Codes typically used to report this service. In most instances Revenue Codes are purely advisory. Unless specified in the policy, services reported under other Revenue Codes are equally subject to this coverage determination. Complete absence of all Revenue Codes indicates that coverage is not influenced by Revenue Code and the policy should be assumed to apply equally to all Revenue Codes.

0300Laboratory - General Classification
0301Laboratory - Chemistry
0309Laboratory - Other Laboratory
0310Laboratory Pathology - General Classification
CPT/HCPCS Codes

Group 1 Paragraph: N/A

Group 1 Codes:
81445TARGETED GENOMIC SEQUENCE ANALYSIS PANEL, SOLID ORGAN NEOPLASM, DNA ANALYSIS, 5-50 GENES (EG, ALK, BRAF, CDKN2A, EGFR, ERBB2, KIT, KRAS, NRAS, MET, PDGFRA, PDGFRB, PGR, PIK3CA, PTEN, RET), INTERROGATION FOR SEQUENCE VARIANTS AND COPY NUMBER VARIANTS OR REARRANGEMENTS, IF PERFORMED
81455TARGETED GENOMIC SEQUENCE ANALYSIS PANEL, SOLID ORGAN OR HEMATOLYMPHOID NEOPLASM, DNA AND RNA ANALYSIS WHEN PERFORMED, 51 OR GREATER GENES (EG, ALK, BRAF, CDKN2A, CEBPA, DNMT3A, EGFR, ERBB2, EZH2, FLT3, IDH1, IDH2, JAK2, KIT, KRAS, MLL, NPM1, NRAS, MET, NOTCH1, PDGFRA, PDGFRB, PGR, PIK3CA, PTEN, RET), INTERROGATION FOR SEQUENCE VARIANTS AND COPY NUMBER VARIANTS OR REARRANGEMENTS, IF PERFORMED
81479UNLISTED MOLECULAR PATHOLOGY PROCEDURE




ICD-10 Codes that Support Medical Necessity

Group 1 Paragraph: N/A

Group 1 Codes:
Search By:

Group 1Codes

ICD-10 CODEDESCRIPTION
C33Malignant neoplasm of trachea
C34.01Malignant neoplasm of right main bronchus
C34.02Malignant neoplasm of left main bronchus
C34.11Malignant neoplasm of upper lobe, right bronchus or lung
C34.12Malignant neoplasm of upper lobe, left bronchus or lung
C34.2Malignant neoplasm of middle lobe, bronchus or lung
C34.31Malignant neoplasm of lower lobe, right bronchus or lung
C34.32Malignant neoplasm of lower lobe, left bronchus or lung
C34.81Malignant neoplasm of overlapping sites of right bronchus and lung
C34.82Malignant neoplasm of overlapping sites of left bronchus and lung