There's even been a court case settled in which documents were filed pivoting on panel coding issues (here).
Finally, MolDx continues to have an older article against code stacking and about panel billing (of either PCR, Sanger, or NGS tests), dating from 2014 (here). This is called "Test Panel Alert M00101."
What's New! A57503!
Flash forward to October 2019 and MolDx drops a new article that stringently defines single gene versus multiple gene test orders (whether PCR, NGS, etc) and how they should be coding. MolDx appears set on enforcing the Correct Coding handbook cited above.
The brand new article is called "Billing and Coding: MolDx: Testing of Multiple Genes" (A57503). Find it on the CMS website here and see a cloud PDF copy here.
A Little Dizzying
The instructions are fairly lengthy, but seem to include using appropriate CPT coding for known panels (e.g. 81432, a ten-gene breast cancer panel), but also covers other situations such as billing for "two or more genes on the same day of service." Whereas the Correct Coding edits referred above only apply to NGS testing (and require 2 or more genes to be billed with 81479, which most payers and MACs would find manual and cumbersome), this new article A57503 is like the Test Panel Alert of 2014, because it applies to any method, whether NGS or not.
It's unclear if this article supersedes the Test Panel Alert for MolDx, that is, if the T.P.A. will be withdrawn from the website. If both MolDx articles are in effect, and the CCI edits, it may be a little confusing. I've put a cloud copy of the T.P.A. article here.
|Three Simultaneous Test Panel Instructions: MolDx, CMS, MolDx|
I've clipped the core text of A57503 below the break.