Commercial Insurance and Colonoscopy CoPay - Post FIT and Post May 2022

    CMS dealt with the colonoscopy copay, after FIT or Cologuard, in last fall's rulemaking (November 2022).  They now view the colonoscopy as a continuous process with the preventive FIT test.

   HHS ruled this applied to commercial insurance earlier.  

   This is based on the exact wording of the USPSTF CRC position in the May 2021 update.  USPSTF used phrases like "integral part of screening" to refer to colonoscopy, and HHS noted in a ACA bulletin that this meant commercial insurance can't charge a copay for either fit nor colonoscopy after fit.

I don't recall that CMS paid that much attention to USPSTF May 2021 in its own reasoning in July/Nov 2022.    But then the CMS benefit stems from the statute as a line item, and the ACA benefit stems from the wording or revisions to USPTF.

Anyway, it's Q7 here.

https://www.cms.gov/CCIIO/Resources/Fact-Sheets-and-FAQs/Downloads/FAQs-Part-51.pdf