How Nationalized is the MolDx Program?

How nationalized is the MolDx Program?   It's easy to go to the public DEX(TM) Diagnostics Exchange website and get some insights.  It's here:  https://app.dexzcodes.com/

Note that on the home page DEX(TM) states that: "The test registry catalog is available for reference and review by other stakeholders in the healthcare system."   When you login, you are greeted by the statement, "The Diagnostics Exchange is an open, online test registry."

DEX allows display of data by institution (lab or hospital) or by test name.  If you display by test name, there are about 14,400 (144 screens at 100 per screen).    Full information on each test is publicly displayed, including the providing lab name, its NPI number, test description, and whether it is covered by Palmetto MolDx.   From the NPI number, you can scrape a separate cloud database at CMS for Medicare payments by CPT code, year, and state, here.  With fairly basic Excel skills, such as the MATCH function, you can pull the different data cells into a common database.   From the lab or hospital name, you can also search for external information, such as federal lobbying donations (here).   That data can also be pulled into the spreadsheet fairly easily by pairing institutional name (in lobbying data) with institutional name and NPI (in CMS data).   

I tallied 1591 institutions registered with DEX(TM).   (Some of multiple registrations under a master registration, e.g. Crescendo Biosciences under Myriad Genetics).   Of the 1591 registrations, 1308 were in MOLDX states (of which I tally 28).   Of these 1308, 624 were in the Noridian MAC, 455 in the WPS MAC, 177 in the CGS MAC, and only 52 in the Palmetto MAC.   For example, there are 290 registrations in California but only 43 in Palmetto's home state of South Carolina.  (South Carolina had fewer MoLx registered institutions than any Palmetto MAC state except West Virginia, which had 16.)  

Outside of MAC jurisdictions, I tallied 283 registrations.  These included 28 in FCSO MAC, 115 in NGS MAC, and 140 in Novitas MAC.

Using 2019 CMS payment data by state, and MOLDX registrations by State, you can calculate state level molecular spending and year-on-year growth rate.  For 3,762,104 Medicare beneficiaries in California, the largest MolDx state, spending on molecular pathology in 2019 was $94.89 per beneficiary, whereas for 2,207,942 Medicare beneficiaries in New York, the largest non-MolDx state, spending on molecular pathology in 2019 was $0.61 cents per beneficiary.  Comparing 2018 and 2019 spending, the growth rate (year on year) was 46% higher in California than New York.   (Bene numbers here, state spending here.)

___

In the past several weeks, both the OIG and the federal Medicare Payment Advisory Committee have issued reports on the growth of molecular pathology spending in the US (here; spending was doubling year on year).   I had previously calculated that nearly all (80%) of US mopath spending is via the MolDx policy program (here).   While I think very highly of the MolDx problem overall, there are clearly some cases of egregious errors in its claims processing rules which you can see by comparing different databases (here).

_____

At the CMS public FOIA website, www.cms.gov, there are posted public records of previous FOIA transactions releasing this data in collated form, e.g. Transaction 09052019C012 (here, here).