As I have discussed on my main blog in multiple articles, there has been an explosion in genomic test Medicare fraud from 2017 to 2018 to 2019. Much of this uses code 81408, a grabbag code applicable mostly for full sequencing of ultra rare genes such as fatal diseases in infants. At $300M in 2019, this was the highest paid of all molecular CPT codes, but only paid in a handful of states (not paid at all in 5 of 7 MACs as "never medically necessary" in Medicare).
CMS has delayed release of CY2018 provider data by CPT code, data that would normally be released in May. See my September correspondence with CMS here.
On October 14, 2020, I made two submission requests to CMS FOIA. One was for code 81408 spending by NPI in 2018 (probably 10-20 data lines), and the other was all MoPath codes by NPI in 2018 (81162-81599).
Model letter as below.
__________________________________________________________
October 14, 2020
CMS FOIA Officer
Centers for Medicare &
Medicaid Services
Mailstop N2-20-16
7500 Security Blvd
Baltimore MD 21244
Dear FOIA Officer:
Under the Freedom of Information
Act, Subsection 552, I am requesting access to the following records:
·
Since 2014, CMS
has annually released data on prior-year utilization of CPT codes, with payment
information, for all participating physicians and laboratories.
·
The release is
usually in May for the calendar year 18 months prior. This represents official agency policy
(January 17, 2014, 79 FR 3205) and has a standard website:
·
Per correspondence
with CMS Medicare Provider Data Team, September 29, 2020, the full public
release of CY2018 data has been delayed from May 2020 to time indefinite.
·
·
I request the
following limited information via FOIA:
o 2018
payments to physicians and laboratories for CPT CODE RANGES:
§ EITHER
81162-81599
§ OR ELSE (EQUIVALENTLY)
o 811xx
o 812xx
o 813xx
o 814xx
o 815xx
§ I believe this will be an excel spreadsheet of about
2000-2500 liones.
§ Key fields include: NPI, Provider last name, city, state, CPT
code range 81162-81599, Number of services, Average Medicare Allowed
Amount.
§ Providing all the data fields per each NPI would
also be acceptable.
I believe the time to obtain
this is reasonable. For 2016 and 2017
data, which is already online at CMS in a cloud database, I can extract this
data in a minute or so.
To determine my status for the
purpose of fees, I am an individual seeking information for personal use and
not commercial use.
In addition, when I identify
suspicious payment information I periodically report this to MACs, or CMS, or
OIG. Disclosure of the requested
information to me is in the public interest because it is likely to contribute
significantly to public understanding of the operations or activities of the
government and is not primarily in my commercial interest.
I am willing to pay fees to a
maximum of $300.
I request information in an
electronic format and either email or CD is OK.
I request this information be
expedited because of recent reports by OIG, by DOJ, in news media, and on my
public blog that there has been a rise in anomalous payments for genetic CPT
codes in 2017, 2018, 2019. My work has
been covered in two recent trade journal news stories and this reflects current
urgency to inform the public concerning actual or alleged Federal Government
activity
CONTACT
If you have any questions you may please telephone me at XYZ. My email is XYZ.
Bruce Quinn MD
649 South Mansfield Ave
Los Angeles CA 90036
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