How Long Might It Take CMS To Implement Rules for a Massive NGS NCD? (Scary)

On November 30, 2017, CMS released a massive draft NCD which would cover the whole domain of next generation sequencing technologies in oncology patients, both those with advanced cancer (where many new controls would be implemented) and those with non-advanced cancer (where NGS technologies would be banned outright).   Comment period closed in January (see comments here) and the final decision will be released on February 28 and effective on the same day.

How long would it take to figure out and implement all the associated rules?   One recent NCD example took a nearly ten month timeline.

• On May 25, 2017, CMS released an NCD covering supervised exercise therapy (e.g. by physcial therapists) for patients with peripheral artery disease.  
• According to some fairly obscure program materials, three months later, they sent an email to Medicare Advantage plans on August 12, 2017, stating that costs under the NCD would be paid by CMS FFS MACs rather than billed to MA plans through the end of CY2018.
• On February 2, 2018, eight months after the NCD was released as final, CMS released "Change Request 10295," aka NCD Transmittal 204, describing the new coverage policy to contractors, with an "effective date" seven months in the past (May 25, 2017) and an "implementation date" of....wait for it...two months in the future at April 3, 2018.
• The corresponding "claims processing" transmittal is here (also Change Request 10295, but a separate file as Claims Processing Transmittal 3969).

Hopefully for the hugely impactful NGS Oncology NCD, CMS could get the rules to medical centers and laboratories and MACs in faster than 8 months -- but that was the actual timeline for this 2017 NCD example