Wednesday, June 24, 2020

Medicare Nerd Note: Getting a PLA Code in time for Next PAMA Pricing Cycle

Summary

The next data collection for PAMA won't occur until 1H2024, for pricing in 2026, 2027, 2028.  

If you have a PLA code being priced now, it won't get a new price under PAMA until 2026.   

If you don't have a PLA code, but you do want to have one in time for the next PAMA cycle, you can apply as late as 7/1/2023 (three full years from today).  And you'll get your effective PAMA price on 1/1/2026 (five and a half years from today).
_______

AMA is currently issuing Proprietary Laboratory Analyses codes at a rate of circa 100 per year.   

One use of these codes, they provide a proprietary price for a lab's test.  A sole source test is eligible for a PLA code, whether FDA reviewed or not; any FDA reviewed test is also eligible for a PLA code.  

PLA codes are initially assigned crosswalk or gapfill pricing by CMS (see this year's pricing meeting here).  But when they hit the next PAMA 3-year pricing cycle the PLA codes get their own proprietary market-based rate.

Absent changes by law in Spring 2020, PAMA data for claims in 1H2019 would have been submitted to CMS now in 1H2020 to set prices for 2021, 2022, 2023.   However, data for 1H2019 claims will now be submitted to CMS in 2022 (!), for price setting in 2023, 2024, 2025.    

This creates an unusually large gap between prior PLA codes (from 2018, used in claims in 2019), and PLA codes from 2019, 2020, 2021, 2022, and 2023, since the next PAMA reporting claims period won't be until 1H2024.   And when those claims are watched in 1H2024, they're for reporting to CMS in 1H2025 for pricing in 2026, 2027, 2028.   

The bottom line is that PLA codes which get crosswalk or gapfill pricing now, in 2020, 2021, won't get new market-based pricing under PAMA until 1/1/2026.    

If you want to have a PLA code to be used in the next round of PAMA data collection, 1H2024, you can apply to the AMA PLA process as late as July 1, 2023 for a PLA code, which becomes effective on 1/1/2024, assuming the rules and regulations around PLA codes don't change.

Graphic below.