Coding and Payment for Genomic Sequencing Procedures (GSPs) and Existing Advanced Diagnostic Laboratory Tests (ADLTs)

Similar documents
Reimbursement for Advanced Diagnostics: Challenges and Opportunities

NEWSFLASH: Quorum Consulting s Guide to the Medicare Clinical Diagnostics Laboratory Tests Payment System Final Rule.

Legislative Symposium

Solicitation of Public Comments on the Protecting Access to Medicare Act (PAMA)

CMS Proposes New Medicare Reporting and Payment System for Laboratories

Laboratory Oversight and Enforcement

The Regulatory & Reimbursement Policy Landscape in Personalized Medicine: A (Payer s) Perspective

Problems with the Current HCPCS Process and Recommendations for Change

June 7, Dear Administrator Verma,

2018 Outlook for the Clinical Laboratory Industry

Medicare s National Correct Coding Initiative (CCI)

Re: CY 2018 CLFS - Preliminary Payment Rates and Crosswalking/Gapfilling Determinations; Comments submitted to

1. Statutory and Regulatory Background

G0434 DRUG SCREEN, OTHER THAN CHROMATOGRAPHIC; ANY NUMBER OF DRUG CLASSES, BY CLIA WAIVED TEST OR MODERATE COMPLEXITY TEST, PER PATIENT ENCOUNTER

Medically Unlikely Edits (MUE)

G0476 INFECTIOUS AGENT DETECTION BY NUCLEIC ACID (DNA OR RNA); HUMAN PAPILLOMAVIRUS (HPV), HIGH-RISK TYPES (E.G

CONNECTIONS CONVERSION TO ICD-10-CM DIAGNOSIS CODING SYSTEM HOLIDAY SCHEDULE

HEALTHCARE COMMON PROCEDURE CODING SYSTEM (HCPCS) LEVEL II CODING PROCEDURES

Payment Policy: New Patient Reference Number: CC.PP.036 Product Types: ALL

Glossary. Adults: Individuals ages 19 through 64. Allowed amounts: See prices paid. Allowed costs: See prices paid.

G0464 COLORECTAL CANCER SCREENING; STOOL-BASED DNA AND FECAL OCCULT HEMOGLOBIN (E.G., KRAS, NDRG4 AND BMP3) Healthcare Common Procedure Coding System

Medically Unlikely Edits (MUE)

MEDICARE S PAMA-BASED CLFS PAYMENT IMPACT: STRATEGIES TO PROTECT YOUR LAB S REVENUE LÂLE WHITE, EXECUTIVE CHAIRMAN AND CEO, XIFIN, INC.

Healthcare Common Prodecure Coding System

Moda Health Reimbursement Policy Overview

Contractor Information. LCD Information. FUTURE Local Coverage Determination (LCD): Molecular Diagnostic Tests (MDT) (L33541)

June 30, 2006 BY ELECTRONIC DELIVERY

Submitted electronically to

Payment Policy: Clinical Validation of Modifer 25 Reference Number: CC.PP.013 Product Types: ALL

LABCORP ANNOUNCES 2018 SECOND QUARTER RESULTS AND UPDATES 2018 GUIDANCE

Contractor Information. LCD Information. FUTURE Local Coverage Determination (LCD): Frequency of Laboratory Tests (L35099) Document Information

Section: Administrative Subsection: None Date of Origin: 1/22/2004 Policy Number: RPM002 Last Updated: 1/6/2017 Last Reviewed: 1/18/2017

Modifiers GA, GX, GY, and GZ

MEDICAL DEVICE REIMBURSEMENT PRESENTED AT ST. THOMAS UNIVERSITY, DESIGN AND MANUFACTURING IN THE MEDICAL DEVICE INDUSTRY COURSE ON SEPTEMBER 30, 2013

G6042 AMPHETAMINE OR METHAMPHETAMINE Healthcare Common Procedure Coding System

Final Policy, Payment, and Quality Provisions in the Medicare Physician Fee Schedule for Calendar Year 2018

G0298 HIV ANTIGEN/ANTIBODY, COMBINATION ASSAY, SCREENING Healthcare Common Procedure Coding System

Coding and Reimbursement Guide

G0103 PROSTATE CANCER SCREENING; PROSTATE SPECIFIC ANTIGEN TEST (PSA) Healthcare Common Procedure Coding System

August 27, Dear Ms. Tavenner,

RAC Preparation Checklist

From Research to Revenue Coverage and Reimbursement for Life Sciences Products

Injection and Infusion Services Policy

ERRATA for Diagnostic & Interventional Cardiovascular Coding Reference 2017 Edition

Medically Unlikely Edits Policy

H.R. 4302, Protecting Access to Medicare Act of 2014 AMA Summary March 28, 2014

All Payer Hospital System Modernization Payment Models Workgroup. Meeting Agenda

Leveraging Real-World Data and Analytics in the Device Industry. Tom Abbott Head, Healthcare Informatics Medical Device & Diagnostics

G0435 INFECTIOUS AGENT ANTIBODY DETECTION BY RAPID ANTIBODY TEST, HIV-1 AND/OR HIV-2, SCREENING Healthcare Common Procedure Coding System

Multiple Procedure Payment Reduction (MPPR) for Surgical Procedures

Medicare s s 2009 eprescribing Program

One or More Sessions Policy

Payment Policy:Modifier to Procedure Code Validation: Payment Modifiers Reference Number: CC.PP.028

Co-Surgeon / Team Surgeon Policy

PAMA. How Did We Get Here and What s Next? Current Reimbursement Issues: Regulatory Trends, Market Dynamics, and Strategies Post-PAMAgeddon

The MPFS payment rates for non-excepted items and services furnished and billed by non-excepted off-campus PBDs, and

Healthcare Common Prodecure Coding System

G0306 COMPLETE CBC, AUTOMATED (HGB, HCT, RBC, WBC, WITHOUT PLATELET COUNT) AND AUTOMATED WBC DIFFERENTIAL COUNT

April 26, Are Payers Getting Tougher? Essential Insights on How to Smooth Acceptance of New Genetic Tests?

Legislative & Regulatory Issues Facing Pathology & Laboratory Medicine. Ronald L. Weiss, MD

Q9960 HIGH OSMOLAR CONTRAST MATERIAL, MG/ML IODINE CONCENTRATION, PER ML Healthcare Common Procedure Coding System

Re: Calendar Year 2018 Clinical Laboratory Fee Schedule (CLFS) Preliminary Private Payor Rates and Crosswalking/Gapfilling Determinations

A9579 INJECTION, GADOLINIUM-BASED MAGNETIC RESONANCE CONTRAST AGENT, NOT OTHERWISE SPECIFIED (NOS), PER ML Healthcare Common Procedure Coding System

Healthcare Common Prodecure Coding System

The Changing Landscape of Medicare's Clinical Trial Coverage Policies for Medical Devices. Michael Sanchez, M.A., CCA Reimbursement Advisor

Reference Guide to Understanding Modifiers

hfma September 21, 2018

Billing for Rehabilitation Services

The Impact of Future Healthcare Reform on MedTech Communications

L8698 MISCELLANEOUS COMPONENT, SUPPLY OR ACCESSORY FOR USE WITH TOTAL ARTIFICIAL HEART SYSTEM Healthcare Common Procedure Coding System

IN THE GENERAL ASSEMBLY STATE OF. Ensuring Transparency in Prior Authorization Act

G8496 ALL QUALITY ACTIONS FOR THE APPLICABLE MEASURES IN THE PREVENTIVE CARE MEASURES GROUP HAVE BEEN PERFORMED FOR THIS PATIENT

G0436 SMOKING AND TOBACCO CESSATION COUNSELING VISIT FOR THE ASYMPTOMATIC PATIENT; INTERMEDIATE, GREATER THAN 3 MINUTES, UP TO 10 MINUTES

Legislative Text Section 218(b), Protecting Access to Medicare Act of 2014 (Public Law No )

February 19, Dear Ms. Verma,

Payment Policy: Unbundled Professional Services Reference Number: CC.PP.043 Product Types: ALL

Meet the Presenter. Welcome to PMI s Webinar Presentation. On the topic: Maximizing the Use of LCDs & NCDs

Pre Market Reimbursement Strategies for New Technologies

Professional/Technical Component Policy, Professional

A9900 MISCELLANEOUS DME SUPPLY, ACCESSORY, AND/OR SERVICE COMPONENT OF ANOTHER HCPCS CODE Healthcare Common Procedure Coding System

Healthcare Common Prodecure Coding System

G0400 HOME SLEEP TEST (HST) WITH TYPE IV PORTABLE MONITOR, UNATTENDED; MINIMUM OF 3 CHANNELS Healthcare Common Procedure Coding System

REIMBURSEMENT INFORMATION FOR DIGITAL X-RAY TOMOSYNTHESIS (DTS) WHEN UTILIZED FOR THORACIC OR ORTHOPEDIC X-RAY EXAMINATIONS i

G8427 ELIGIBLE CLINICIAN ATTESTS TO DOCUMENTING IN THE MEDICAL RECORD THEY OBTAINED, UPDATED, OR REVIEWED THE PATIENT'S CURRENT MEDICATIONS

Medicare Outpatient Prospective Payment System for Calendar Year 2014

PRESCRIPTION MEDICINE PRICING OUR PRINCIPLES AND PERSPECTIVES

2019 Hospital Outpatient and Ambulatory Surgery Payment Systems (OPPS) Proposed Rule Summary (Last revised on July 28, 2018)

Healthcare Common Prodecure Coding System

UnitedHealthcare Medicare Advantage Reimbursement Policy CMS 1500 Multiple Procedure Payment Reduction (MPPR) for Therapy Services Policy

(1) Ambulatory surgical center (ASC) means any center, service, office facility, or other entity that:

Challenges in Maintaining a Laboratory Compliance Program

E1399 DURABLE MEDICAL EQUIPMENT, MISCELLANEOUS Healthcare Common Procedure Coding System

APPENDIX. Methodology COST AND UTILIZATION 2018 REPORT MN Community Measurement. All Rights Reserved.

Payment Policy Medicine

G0475 HIV ANTIGEN/ANTIBODY, COMBINATION ASSAY, SCREENING Healthcare Common Procedure Coding System

G8447 PATIENT ENCOUNTER WAS DOCUMENTED USING AN EHR SYSTEM THAT HAS BEEN CERTIFIED BY AN AUTHORIZED TESTING AND CERTIFICATION BODY (ATCB)

Discarded Drugs and Biologicals

BWC ASC Fee Schedule 2009 Update. Anne Casto, RHIA, CCS Casto Consulting, LLC

Know, Prepare and Comply with the Sunshine Act Phase 2. John A. Murphy, III, Assistant General Counsel PhRMA August 26, 2014

FOR PHYSICIANS. CMS will collect the data annually, aggregate it, and publish it on a public website.

Transcription:

Coding and Payment for Genomic Sequencing Procedures (GSPs) and Existing Advanced Diagnostic Laboratory Tests (ADLTs) Clinical Laboratory Fee Schedule Public Meeting July 16, 2015 Baltimore, MD

Coalition for 21st Century Medicine The Coalition represents the world's most innovative diagnostic technology companies, clinical laboratories, researchers, physicians, venture capitalists and patient advocacy groups all linked by a common mission: to develop and commercialize state-of-the-art diagnostics that improve patient health.

Genomic Sequencing Procedures C21 Supports the 2015 Final Payment Decision for Targeted GSPs : For GSP codes CMS should continue to allow MAC contractors to set payment by gapfill when the Medicare contractor determines the code is payable. Contractors should be allowed to develop and use unique test identifiers for GSP procedures. Rationale: Local contractor determination. A wide variety of tests can be described by each GSP code, extended dialogue between the laboratory/manufacturer and the entity making the coverage determination is necessary to ensure that an appropriate coverage decision is made. Gapfill. The GSP code category was created as a distinct code category because these codes are unlike anything else on the CLFS. Because there are no analogues in the existing CLFS, gapfill remains the best option for determining the payment amount. Consistent with the policies underlying PAMA, contractors should review commercial payer rates, among other data points, to determine Medicare payment. Unique test identifiers. Allowing contractors to establish and use unique test identifiers is consistent with CMS s transparency interests: Unique test identifiers allows CMS and its contractors to identify claims submitted.

2016 CLFS Recommendation On or before January 1, 2016, CMS should adopt and publish the CPT codes for Existing Advanced Diagnostic Laboratory Tests (ADLT) issued by the AMA On or before January 1, 2016, for each Existing ADLT CMS should publish the local payment rate of the MAC who issued a local coverage determination for the Existing ADLT These recommendations are consistent with requirements under Section 216 of the Protecting Access to Medicare Act (PAMA)

Background PAMA created special payment and coding rules for certain Existing ADLTs paid by the Medicare program as of the date of enactment (04/01/2014), requiring that Existing ADLTs be assigned unique codes and that payment rates for these unique codes be publicly posted by January 1, 2016 PAMA also created a transitional rule to allow CMS to use existing methodologies, including gapfill or crosswalk, to establish payment rates for new lab tests that had not already been priced by CMS or the MACs In response to PAMA, AMA put out a special stakeholder notification for existing ADLT code applications. As a result, eight existing ADLTs were assigned new CPT codes and are included on today s Agenda.

ADLT Definition under PAMA (5) ADVANCED DIAGNOSTIC LABORATORY TEST DEFINED In this subsection, the term advanced diagnostic laboratory test means a clinical diagnostic laboratory test covered under this part that is offered and furnished only by a single laboratory and not sold for use by a laboratory other than the original developing laboratory (or a successor owner) and meets one of the following criteria: (A) The test is an analysis of multiple biomarkers of DNA, RNA, or proteins combined with a unique algorithm to yield a single patient-specific result. (B) The test is cleared or approved by the Food and Drug Administration. (C) The test meets other similar criteria established by the Secretary. Soc Sec Act 1834A(d)(5)

Requirement for Existing ADLTs (2) Existing Tests Not later than January 1, 2016, for each existing advanced diagnostic laboratory test (as so defined) and each existing clinical diagnostic laboratory test that is cleared or approved by the Food and Drug Administration for which payment is made under this part as of the date of enactment of this section, if such test has not already been assigned a unique HCPCS code, the Secretary shall (A) assign a unique HCPCS code for the test, and (B) publicly report the payment rate for the test. Soc Sec Act 1834A(e)(2)

New Codes Effective January 1, 2016 for Existing ADLTs AMA issued a special stakeholder notification for ADLTs meeting the following criteria: Were paid by Medicare Qualify as an ADLT In response to the AMA, eight Existing ADLTs that meet the AMA criteria received Category I MAAA codes that will be effective January 1, 2016 Prior to being assigned a Category I MAAA code, the MACs with jurisdiction for establishing coverage for each test determined payment rates and provided individual coding instructions to the laboratories billing for these tests

Existing ADLTs and July Public Meeting CMS is required to publish a payment rate for these Existing ADLTs on January 1, 2016 In the past two rate setting cycles, CMS has determined MAAA rate-setting by instructing contractors to gapfill rates when the contractor determines that a test is payable If CMS follows the same approach this year and leaves ratesetting for contractors to gapfill these codes next year, the PAMA requirement to publish a rate on January 1, 2016 will not be met

Transitional Rule (i) TRANSITIONAL RULE During the period beginning on the date of enactment of this section and ending on December 31, 2016, with respect to advanced diagnostic laboratory tests under this part, the Secretary shall use the methodologies for pricing, coding, and coverage in effect on the day before such date of enactment, which may include cross-walking or gapfilling methods. Soc Sec Act 1834A(i)

Application of Transitional Rule Transitional rule was intended to provide CMS the ability to price new lab tests, that had not already been priced by CMS or the MACs, in the period between PAMA passage and implementation CMS can use July meeting along with gapfilling or crosswalking to establish transitional payment rates until full market rates are established

Recommendations On or before January 1, 2016, CMS should adopt and publish the CPT codes for Existing ADLTs issued by the AMA On or before January 1, 2016, for each Existing ADLT CMS should publish the local payment rate of the MAC who issued a local coverage determination for the Existing ADLT To meet the PAMA publishing requirement, CMS may: Publish the codes and rates in the PAMA Final Rule; or Publish the codes and rates in the CLFS Final Payment Determinations for 2016

Thank you!