Friday, July 26, 2019

AMA's Sudden Unexpected New PLA Code Rules: Once a PLA, Always a PLA?

The AMA holds 3 CPT editorial panel meetings a year, and AMA publishes a summary of actions about a month after each meeting (here).   The most recent summary is from May 2019's meeting in Chicago (here).

At that latter link, see Tabs 53, 54.

In these summaries, AMA panelists voted that if a PLA code (the product represented by the PLA code) is later approved for full-fledged AMA Category I status, it will remain in the PLA appendix but will be tagged with an arrow symbol.   A secondary policy is that if a code is pending as a Category I code, you can't create an interim short term PLA code for it.  You have to just sit tight til the Category I code is published.

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Corresponding text will be published in the 2020 code book, which appears soon, in September/October 2019.

Implications

I tallied the latest 103 PLA codes (including those under consideration for Q32019 now), and estimated that about 25 represent MAAA codes.  These are proprietary tests which, with wide acceptance, would be (or would always have been) eligible to be Category I MAAA codes as numbered as such (815xx).  Now, that won't be possibly if they've already become PLA codes.

So far as I know, an Administrative MAAA code can still be elevated to a Cat I (815XX numbered) code.

Not How Category III Codes Are Treated

PLA codes are rapidly issued codes, as are Category III codes.  However, when a product (service) in Category III codes meets criteria for Category I, the AMA elevates the code to a newly number Category I status.  It does not simply add an arrow-sign to the Category III code

But Wait, There's More: September Policymaking re PLA Revisions

The September 2019 AMA meeting in Seattle will also have some PLA policymaking.  Agenda item deals with new policies for when PLA revisions are allowed versus when a PLA code needs to be deleted and restarted as a new code.

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Finally - Any Barrier Between PLA and Category I Codes Likely a Leaky Barrier

The barrier to be erected between PLA World and Category I numbering seems to be somewhat leaky. 

For example, I tallied about 17 codes of 103 that I estimated could appear in the future as Category I codes as non-branded codes.  For example, let's say one lab gets an early PLA code for gene XYZ.  A couple years later, XYZ is a gene with wide use for several cancer drugs.  So AMP or CAP might create XYZ as a category I code.   It would be a code everyone could use and the original PLA applicant might or might not choose to delete his own code if pricing or coverage were better for the new general-usage XYZ code.