Thursday, April 9, 2026

Tamara Syrek Jensen - The Medtech Strategist Interview

Medtech Strategist has released an interesting podcast interview.   Learn about Tamara Syrek Jensen's career at CMS, much of it in the Coverage Group, and the insights she brings to clients today as a Principal of Rubrum Advising.

(Note, she seems to say a couple times, CMS is where I am; but it's clear she was out-of-government at this interview and working with Lee Fleisher at Rubrum Consulting.)

Find the podcast here:

https://www.medtechstrategist.com/podcast-content

Look for Podcast #34.  She's interviewed by Stephen Levin, edtior-in-chief.

Or find their YouTube audio channel here:

https://www.youtube.com/watch?v=dNK8ZhJZEYQ



Chat GPT listened in and reports for us:

In a candid Market Pathways interview, former CMS coverage chief Tamara Syrek Jensen argues that reimbursement bottlenecks are structural, not merely bureaucratic—spanning evidence, coding, payment, Medicare Advantage, and payer coordination—while urging earlier, honest, disciplined engagement among industry, CMS, and FDA.

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Tamara Syrek Jensen on CMS After 25 Years:
A Reimbursement Insider Explains What Industry Still Gets Wrong

Market Pathways’ interview with Tamara Syrek Jensen is valuable not because it offers a grand reimbursement fix, but because it strips away a few durable myths. Jensen, who spent roughly 25 years at CMS and the last decade leading the Coverage and Analysis Group, speaks with unusual directness about the agency’s constraints, the industry’s misconceptions, and the widening gap between regulatory success and payment success. The conversation, drawn from the San Diego Innovation Summit, is framed by Stephen Levin as a rare chance to hear a former CMS official speak frankly about Medicare reimbursement, parallel review, and the practical difficulties companies face in working with CMS.

The central point is one sophisticated readers already suspect but often understate: reimbursement is not “FDA, but slower.” Jensen emphasizes that payment is an ecosystem problem, not a single-agency problem. Coverage, coding, and payment remain the classic “three-legged stool,” but in her telling that stool has effectively become four-legged because Medicare Advantage now sits on top of the traditional fee-for-service architecture. Add private payers, the AMA, specialty societies, and MAC behavior, and the contrast with FDA becomes stark: regulation can be grueling, but it is still largely one-agency navigation; reimbursement is a distributed negotiation across multiple institutions, standards, and incentives.

That matters because Jensen rejects the cartoon version of CMS as simply the lagging “problem child” after FDA approval. She says CMS had been trying, including behind the scenes, to explore whether certain NCDs could be made much shorter and faster, closer to the timing of FDA action. But even a rapid coverage decision is insufficient if coding is absent or payment is effectively zero. Her point is not defensive so much as architectural: reimbursement failures are often compounded failures. A positive regulatory event does not automatically propagate into a usable reimbursement pathway, and companies that model it that way are modeling the wrong system.

For companies, Jensen’s most practical message may be cultural rather than procedural. She openly acknowledges that bias against industry has existed inside government, just as industry carries its own bias against CMS. But she also makes a sharper distinction: distrust is manageable, dishonesty is corrosive. Her formulation is memorable in its simplicity—“Just be honest”—and it comes with an implicit warning. When manufacturers tell CMS one story and FDA another, they are not just creating confusion; they are degrading the possibility of creative problem-solving. By contrast, she describes a more recent “paradigm shift” in which companies are more willing to admit evidentiary imperfection while still arguing that a technology benefits patients. That, she suggests, is the kind of conversation from which CED and TSET-type solutions can actually emerge.

Her comments on transparency are equally pointed. Jensen does not deny that CMS has historically been experienced as opaque. She more or less concedes the criticism, while arguing that openness—within legal limits—was necessary precisely because silence breeds mythology. If companies cannot get clear signals from the agency, they fill the void with stories about hostility, indifference, or hidden rules. Her preferred answer was repeated conversation, not because repeated meetings are efficient, but because they are trust-building. That is a notable stance from a former Coverage and Analysis Group leader: not that CMS could or should say yes more often, but that it needed to talk more clearly, earlier, and more often about why the answer might be yes, no, or not yet.

On substance, Jensen is especially strong on the question of what CMS is actually evaluating. She pushes back on the industry complaint that “reasonable and necessary” is too undefined to be operational. Her response is that the record is hardly empty: hundreds of NCDs already reveal the endpoints and evidentiary instincts CMS uses, especially as they relate to the Medicare population and its comorbidity burden. More interestingly, she warns that formalizing the standard too tightly could backfire. A rigid statutory or regulatory definition might deliver more certainty in theory while freezing out future technologies in practice. For an audience steeped in coverage policy, that is one of the interview’s more consequential arguments: ambiguity is frustrating, but some ambiguity may be the price of adaptability.

Her skepticism toward reimbursement legislation follows the same logic. Jensen does not dismiss legislative reform reflexively; she worries about implementability. She cites prior statutory efforts that failed because Congress wrote requirements CMS could not realistically operationalize. In the current debate over accelerated coverage concepts, her concern is that proposals can place the entire burden on government—pay first, sort out the evidence later—without symmetrical obligations on manufacturers to produce meaningful Medicare-relevant endpoints within a defined period. For Jensen, temporary coverage without credible downstream accountability is not a bridge but a drift state. That argument will resonate with readers who have watched enthusiasm for transitional coverage repeatedly collide with evidence generation problems in the real world.

The same realism shapes her criticism of parallel review. She does not dispute the idea; she disputes the physics. Early FDA-CMS collaboration is good, she says, but true parallelism is extraordinarily difficult when CDRH operates at a vastly different scale and under rigid review timelines while CMS coverage staff are far smaller in number and are trying to assess Medicare-specific value, not just safety and effectiveness. In one of the interview’s starkest operational details, she notes that the Coverage and Analysis Group had about 30 people, with only around 10 writing NCDs. For experts accustomed to discussing “alignment” at the policy level, this is the grounding reminder: some reimbursement problems are not conceptual failures but capacity mismatches.

What gives the episode extra relevance is timing. Syrek Jensen now speaks from outside government, having recently joined Rubrum Consulting, led by former CMS chief medical officer Lee Fleisher, and that shift gives her remarks both freedom and consequence. She is no longer explaining CMS from behind the seal; she is translating it from just beyond the door. The result is not a manifesto and not a grievance session. It is something rarer: a high-level reimbursement practitioner explaining that the system’s biggest problems are real, that many are structural, and that progress will depend less on rhetorical demands for “faster CMS” than on earlier evidence planning, more honest cross-agency engagement, and a better grasp of what Medicare is actually being asked to buy.

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Her Background

She describes her path as “organic” rather than planned. In her telling, she was a fun-loving undergraduate who later “grew up” and got serious. Her first job after college was on Capitol Hill, where she worked in policy; her boss sat on Ways and Means, which exposed her early to the legislative side of CMS and Medicare. From there, she decided to pursue law, but did it the hard way: she worked at CMS while attending law school at night.

Inside CMS, she says she then rose through a series of roles rather than following a master plan. She started as an analyst on conditions of participation, moved into a special assistant role for the Chief Medical Officer, gained a broad view of the agency, and eventually landed in the Coverage and Analysis Group, where she later became its leader. She also emphasizes the importance of informal mentors who guided her along the way.

The Most Surprising Three Remarks

1. Her direct statement that parallel review essentially “doesn’t work” in practice.

That is striking because parallel review is often discussed as a high-level policy solution, but she reduced it to operational reality: FDA’s device center has thousands of staff, while the Coverage and Analysis Group had about 30 people, with only about 10 writing NCDs. She said the idea is good, but the timing and staffing mismatch make true parallel review extremely hard to execute.

2. Her unusually candid admission that anti-industry bias at CMS was real — and that she herself probably had some of it.
Former officials almost never say that so plainly. She added that a major source of mistrust was when manufacturers told CMS one thing and FDA another, and she framed honesty as the key condition for productive engagement. That was a notably direct acknowledgment from a former top CMS coverage official.

3. Her remark that the “four years” in the accelerated-coverage style legislation was basically “a random number we made up.”
That is a remarkable thing to say out loud. More broadly, she argued that if government is required to cover a technology for four years, industry must carry a real burden to generate evidence, with consequences if it fails. That cuts against any simplistic “coverage first, evidence later” narrative.

Honorable mention: her blunt line that “the claim system is a yes system.” That is a very revealing description of why CMS is drawn to prepayment integrity tools like Wiser.

CMS Webinar on PAMA Lab Data Submissions: Video Apri 16, but Live Webinar is Closed

Here's new from CMS about PAMA sales price reporting, due at CMS in May-June-July 2026.
The live webinar is sold out, but hopefully they will post archive video.
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CMS press release:


Clinical Diagnostic Laboratories: Get Ready to Report Starting May 1

Are you an independent laboratory, physician office laboratory, or hospital outreach laboratory that meets the definition of an applicable laboratory under the Clinical Laboratory Fee Schedule (CLFS)? If so, you must report data from May 1 – July 31, 2026, based on an updated data collection period of January 1 – June 30, 2025, including:

  • Applicable HCPCS codes
  • Associated private payor rates 
  • Volume data

How do I report?

  1. Review CLFS Data Collection System resources:
  2. View the applicable HCPCS codes (ZIP) 
  3. Use the Data Reporting Template (ZIP) 

More Information:

 Clinical Lab Fee Schedule Data Collection Webinar – April 16

Thursday, April 16 from 3–4 pm ET

[Sold out as of April 9]

Register for the webinar.

Clinical laboratory representatives: You may be required to submit data to CMS in the Fee-for-Service Data Collection System Clinical Lab Fee Schedule (CLFS) Module starting May 1. During this webinar, we’ll:

  • Provide an overview of this data collection initiative
  • Highlight how clinical laboratories can determine whether they’re applicable labs
  • Discuss preparation activities and resources
  • Demonstrate the CLFS Module, including user roles and how to register

We encourage you to submit your questions in advance to CLFS_Inquiries@cms.hhs.gov with “CLFS Webinar” in the subject line.

More Information:

  • Visit the CLFS webpage for official guidance on reporting data
  • Read the FAQs

Phillips et al in SCIENCE: Diagnostics and Policies for Value

In the April 9, 2026, issue of SCIENCE, see an article by Phillips, Horn, & Califf on the value of diagnostics and good diagnostics policy.   It's titled:

  • Diagnostics investments and disease burden
  • Regulatory and payment policies could facilitate investment and innovation in diagnostics
Find it here - (firewalled).
Find a detailed UCSF press release here.


Here's the abstract:
  • Screening and testing for disease using “diagnostics” (see the box) is increasingly essential across global health care systems to identify and target individuals who will most benefit from health care interventions and to address unmet disease burden. However, access to diagnostics is uneven and often inadequate, particularly in lower- and middle-income countries, with an estimated 47% of the world’s population having limited or no access to diagnostics (1). 
  • Despite these needs, diagnostics historically have received lower investment, insurance coverage, and payment rates than drugs, creating barriers to innovation (2). 
  • We leverage a recent, in-depth assessment of the mismatch between drug development and disease burden in the US (2) to address two critical gaps: 
    • (i) policies specifically relevant to diagnostics and integrated diagnostic–drug combinations, and 
    • (ii) how findings for the US extrapolate globally. 
  • We focus on underinvestment in diagnostics and explore how regulatory and payment policies could facilitate diagnostic innovation.
  • ###
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Here's a news report on the article from Chat GPT 5.
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Science paper argues the real bottleneck in precision medicine is diagnostics, not drugs

A Policy Forum published Thursday in Science delivers a familiar complaint in unusually blunt terms: health systems are celebrating targeted drugs while underfunding, underpaying, and under-prioritizing the diagnostic tests that determine whether those drugs should be used at all. The paper, by Kathryn A. Phillips and Danea M. Horn of UCSF and former FDA commissioner Robert Califf, argues that this mismatch is now large enough to impede both innovation and patient care.

For expert readers, the striking point is not that diagnostics matter. That is old news. The sharper claim is that diagnostics are being systematically disadvantaged by the structure of regulation and reimbursement. The authors say that tests are typically evaluated and paid for separately from the therapies they inform, even when the test is clinically necessary for the appropriate use of the drug. In their telling, the result is a fragmented market in which the treatment captures the value and the test absorbs the uncertainty.

The paper is a policy analysis rather than a new clinical or claims-based study, but it arrives with a few numbers designed to crystallize the imbalance. It cites an estimate that 47% of the world’s population has limited or no access to diagnostics. It also reports that from 2015 to 2024, 26.0% of drugs received accelerated approval, versus 4.6% of diagnostics receiving Breakthrough Device Designation, the roughly analogous expedited pathway for devices. The implication is not simply that tests move more slowly, but that the system offers manufacturers weaker reasons to pursue ambitious evidence generation in the first place.

Phillips, Horn, and Califf frame the problem as one of misaligned incentives. Drug developers can often justify large investments because the downstream commercial path is relatively legible. Diagnostics developers, by contrast, face a harder evidentiary problem, since a test provides information rather than direct treatment, and must often prove not just analytic performance but some link to clinical utility. That burden is compounded by the fact that coverage and payment frequently remain unclear even after regulatory progress. The authors describe a feedback loop in which uncertain reimbursement suppresses investment, which in turn suppresses the sort of evidence payers say they want.

Two examples anchor the article. One is GLP-1 therapy for obesity and diabetes. The paper notes that although the class is clinically and commercially transformative, a meaningful share of patients do not respond or discontinue treatment within a year. Yet there is no validated diagnostic to predict likely response before treatment begins. For the authors, that is precisely the kind of missed opportunity created by a system that rewards therapeutics more reliably than the tests that could target them.

The second example is Alzheimer’s disease, where the authors see a particularly conspicuous policy asymmetry. New anti-amyloid drugs can cost roughly $30,000 annually in the United States, while blood-based biomarker tests that could help identify appropriate patients are priced around $1,000. Even so, the paper says reimbursement for those tests remains unclear or absent. It points to Lumipulse as a case in point: a blood-based test with European regulatory approval, FDA Breakthrough Device Designation, and US availability through LabCorp, but no published evidence of insurer coverage as of March 2026. For a field now trying to operationalize treatment selection at scale, that gap is more than symbolic.

What the authors want is not simply higher payment for tests. They are asking for a more integrated policy architecture. Their recommendations include broader use of expedited pathways for diagnostics, more joint review of tests and therapies for both regulatory and payment purposes, better incentives for collecting real-world evidence on clinical utility, and value assessments that examine diagnostic-guided care as a combined intervention rather than treating the test as a narrow cost input. They also point to CMS’s Coverage with Evidence Development as one mechanism that could, at least in principle, support this kind of evidence generation, though they note it has been used far more often for devices than for diagnostics.

The global angle is also worth noting. The authors do not treat this as a purely American coding or Medicare problem, even if many of the examples are US-facing. They point to international harmonization efforts such as the International Medical Device Regulators Forum and to Europe’s Health Technology Assessment Regulation as signs that at least some jurisdictions are beginning to think more systematically about how diagnostics fit into innovation policy. Still, the paper suggests that most health technology assessments remain far more comfortable pricing the drug than valuing the information that makes the drug usable.

For policy insiders, the paper’s real significance may lie in how directly it tries to reposition diagnostics. This is not an argument that tests are ancillary tools deserving modest technical cleanup. It is an argument that diagnostics should often be treated as essential components of therapeutic strategy, with regulatory, evidentiary, and reimbursement pathways built accordingly. That is a bigger claim, and a more disruptive one, because it challenges the longstanding habit of letting therapeutics define value while diagnostics justify themselves piecemeal.

In that sense, the paper reads as both a diagnosis and a warning. Precision medicine can keep producing increasingly sophisticated drugs, but if the tests needed to identify the right patients remain stuck in lower-status regulatory and payment channels, the field risks building a treatment paradigm whose most expensive components are better supported than its decision tools. For a system that prides itself on targeted care, that is an awkward contradiction.

 

Tuesday, April 7, 2026

CMS "CRUSH" Comments Website is Flaky

Update - The website is still flaky, but a bit more on that.  If you search for ACLA, you will in fact pull up 1 thing, the ACLA comment.  This has many mentions of "MolDx" but if you search "MolDx" you will not get ACLA.  

Also, when I searched on "Blue Cross Blue Shield" I got a comment about MolDx being related to BCBS South Carolina, but I didn't get the big 54 page BCBS comment itself.   So it's easy to confirm, it's "flaky," but with a couple extra angles of flakiness.

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In the past few days, I've highlighted the ACLA comment on "CRUSH" (the CMS fraud initative), the ACLA letter being on the ACLA website.  I've also noted that BCBS commented on CRUSH and MolDx, having seen the BCBS 54 p letter posted in a Linked In article.

You can't find these (or my letter) from the CMS website, at least not yet.

If you go to the CRUSH website, https://www.regulations.gov/docket/CMS-2026-0826

...it says 768 comments submitted, and  341 posted.   (Comments were due a week ago).

Among the 341 posted, I searched for "MolDx" (capitalization did not matter) and it gave me 17.  

But not found are the ACLA letter, the BCBSA letter, nor, for example, my own letter.   



What you get is almost entirely individuals who are complaining to CMS that MolDx has not covered a ductal carcinoma related test.   (NOT a comment on the CMS fraud initiative.)

click to enlarge


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Hopefully CMS just has a backlog of post-able comments (768 submitted - 341 so far online = 427 remaining) and will eventually post them all.   

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Here is a four-page anti-MolDx letter.  It emphasizes the need for, and increasing difficulty of, 87798 payments, recently targeted for anti-fraud actions at some MACs.

https://downloads.regulations.gov/CMS-2026-0826-0225/attachment_1.pdf


Released:; Chaihorsky et al., A New White Paper on the "Laboratory 2.0" Vision

 At Linked In, see a new 16-page paper about the vision for "Clinical Laboratory 2.0," by Chaihorsky, Van Ness, Cooper, and Shotorbani.  Authors are from the consultancy Alva10, Wuscott LLC, and the Project Santa Fe Foundation.

Link here.


Abstract,

Clinical laboratories are facing significant economic pressure as the Protecting Access to Medicare Act (PAMA) driven reimbursement cuts erode margins and fee-for-service models become unsustainable. At the same time, nearly half of U.S. healthcare payments now flow through value-based arrangements, creating a pivotal opportunity for laboratories to realign with this new paradigm. This paper outlines a roadmap for how laboratories can transform from transactional test providers into strategic partners in population health, which also catalyzes their transformation from cost centers to revenue generators. Drawing from Project Santa Fe Foundation's Clinical Lab 2.0 framework, it demonstrates how laboratory insights can drive measurable financial and clinical impacts, such as identifying undiagnosed chronic conditions that unlock risk-adjustment revenue and improve quality ratings tied to Medicare Advantage (MA) bonuses. A Business Model Canvas defines the key pillars of this novel business model, and a four-step implementation toolkit equip laboratory leaders and pathologists to align operations, informatics, and partnerships with value-based care principles. The result is a framework for a sustainable, data-driven model positioning laboratories as essential catalysts of health-system performance.

Chat GPT Can Now Write 20-page Reports with 30 Citations ("Deep Research")

My subscription version of Chat GPT ($20/mo) recently got a new function called "Deep Research" (an option on the left-hand menu.)

This week, I asked it to write a report on value-based cancer care, what has held back the field, and whether new kinds of metrics (maybe using AI) could have a big impact.

Chat GPT thought for 45 minutes, and wrote a report (17-page PDF) with some 30 specific footnotes, divided into substantial and content-heavy sections.  There are also some tables and graphics.

How good is it?  Well, it's pretty interesting and could, at a minimum, serve as start-up orientation to someone who wanted to dig into this topic.  

##

AI summarizes its own report - 

This 18-page report is a policy brief, research synthesis, and conference-planning memo rolled into one. 

Structurally, it moves from an executive summary to sections on why VBCC measurement has underperformed, what measures would better support VBCC, what is lacking today, a future-state vision to 2030, and then a staged roadmap with milestones, governance needs, suggested panelists, and decision-point questions. It also includes a comparative candidate-measures table, a timeline, a flowchart, and a numbered bibliography grounded mainly in CMS/CMMI, ONC, NCI, HL7/mCODE, and peer-reviewed oncology outcomes literature.

The core takeaway is that value-based cancer care has not mainly stalled because of weak payment experiments, but because the measurement system is too claims-centric, process-heavy, fragmented, and poorly tied to patient-centered oncology outcomes. The report argues for a smaller core set of 8–12 digitally computable, equity-stratified measures, especially around ePRO symptom control, function, appropriateness, timeliness, end-of-life care, financial toxicity, and HRSN/equity supports.

As an AI artifact, it is a strong example of “Deep Research Writing Mode”: not just summarizing sources, but assembling them into a decision-ready framework with assumptions, analytic scaffolding, implementation logic, and concrete next-step questions. 

In that sense, it reads less like an essay and more like an AI-authored strategic operating document.



Blue Cross to CMS: Nationalize MolDx Now!

This winter, CMS proposed a wide anti-fraud initiative called CRUSH, taking comments until March 30.  Two targets were (1) genomics fraud and (2) DME fraud.   In an earlier blog, I covered the ACLA comment, includings their remarks on MolDx.

At least 17 of the public comments involved MolDx.   This includes the 50-page BCBS comment, which supports the proposed nationalization of MolDx.

Read the full BCBS comment here.  I'll quote the MolDx portions below. 

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See Ashley Zarling's blog at Linked In on the growing role of MolDx, here.

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Wednesday, April 1, 2026

Quick Access to Top Providers of any "Popular" Part B CPT Code. OpenMedicare.US

 CMS group "Data.CMS.Gov" has an elaborate website for payments to providers by CPT code.  It's a little tricky to use but powerful.  Find it here:

https://data.cms.gov/provider-summary-by-type-of-service/medicare-physician-other-practitioners/medicare-physician-other-practitioners-by-provider-and-service

There's a nonprofit website OpenMedicare.US, that lets you look up the providers of any CPT code in a simple way.

https://www.openmedicare.us/procedures/81479

You can go here:

https://www.openmedicare.us/procedures

and then scroll down to "search by code or description."  Note, however, they only provide "top 500 codes" and that's among all procedures, not just lab procedures.  

For example, 81479 (unlisted code) makes the top 500, as does 88342 (IHC), while 81162 (BRCA) does not.  When you can't get granular listings, it still offers you the national spend.  


Here's top data for 88342 IHC:




AMA CPT Publishes Latest Batch of Quarterly PLA Codes

 On April 1, 2027, AMA CPT released the results on the latest batch of quarterly PLA codes.  These codes were applied for around December 10, published today, and active July 1

AMA summarizes there were 2 revisions, 4 deletions, and 29 new codes 0631-659U.

https://www.ama-assn.org/system/files/cpt-pla-codes-long.pdf

Note that AMA includes a number of important instructions for acceptable or disallowed PLA codes, in the two page prolog to the code list.  E.g. "PLA codes do not have a physician work component," which the PLA committee will review rigorously.

##

The next PLA date is April 14, when they will post new code applications for comment, being codes applied-for around March 10.  Those will be hustled through the system from the April 21 public comment date to the Aprl 30 CPT editorial voting date.  The codes should appear in the June and July CMS pricing meetings.





Will CMS Nationalize MOLDX? Coverage at 360DX

A month ago, CMS announced a major new anti-fraud initiative, called CRUSH.  It had two main targets: DME fraud and genomics fraud.  The comment period closed on March 30, and journalists are sorting through the comments received.


See coverage by Adam Bonislawski here (subscription).   (See my CMS comment here).

I see a Regulations.gov posting that 768 comments were received but I haven't found the "search them" link yet.  

Here's the 18-page comment from ACLA - the fact it runs 18 pages alone, suggests they are taking this very seriously.

(Separately, see BCBS 54page CRUSH comment here.)

Here's a 120 word AI overview of the 2000 page full article.

  • Stakeholder comments on the CMS fraud RFI show a divided but nuanced response to possible nationwide MolDX expansion. Lab groups and consultants generally agree that fraud in molecular testing is a real problem and that clearer front-end controls could help. However, their comments emphasize that MolDX also brings slower coverage timelines, heavier documentation demands, and uncertainty for new test launches. 
  • ACLA stressed delays and stalled coverage requests; NILA argued CMS should focus more on inappropriate ordering than on labs alone; consultants noted MolDX can improve predictability once coverage is secured, but at the cost of greater upfront burden. 
  • The overall tone of stakeholder comment was not anti-oversight, but cautionary: many support stronger anti-fraud tools, yet want CMS to avoid replacing one problem—improper payments—with another—bureaucratic delay and reduced patient access.
And here's a longer summary of the open-access ACLA comment:

Tuesday, March 31, 2026

New to Me: AMA Comment Deadlines are NOON CENTRAL on the Day

 New to me, so I'm just flagging this.

The last few weeks, comments have been accepted for the April 30 - May 1 AMA CPT meeting.  One important topic is revisions to Appendix S, a major ongoing issue that affects AMA CPT policy for software-intensive services (e.g. AI).

The comment deadline is March 31 2026, I had that right.

I for one, had not noticed the specific deadline is 11:59 am Central Time (e.g. NOON on the deadline day.)

Something to keep track of.  This applies to pathology comments, non pathology comments, PLA comments, etc.






Monday, March 30, 2026

Horizons in Diagnostics Value: Case Study: Rethinking Value for Infection Diagnostics

Here's a paper that is worth discussion, and potentially applicable to many areas of diagnostics, not just infection.

In a 2025 paper at Open Forum Infectious Diseases, some excellent thought capital is created by Claeys, Prinzi, and Timbrook.  Here.



It's also a great example of a good abstract - I can't do better than quoting it.

  • Evaluating the clinical impact of in vitro diagnostic tests (IVDs) for infectious diseases is complex given their effectiveness depends on context, implementation, and provider behavior. 
  • Traditional methodologies for therapy interventions do not adequately capture this complexity, necessitating novel analytical approaches and study designs. 
  • This review highlights methodological considerations for improving evidence generation for infectious diseases IVDs. 
    • Design and analysis challenges leading to bias and related solutions are reviewed such as the target trial framework. 
    • Moreover, novel frameworks such as Benefit–Risk Evaluation of Diagnostics: A Framework, Desirability of Outcome Ranking Management of Antimicrobial Therapy, and Desirability of Outcome Ranking and study designs such as hybrid effectiveness–implementation designs are discussed which allow for holistic ways to assess real-world outcomes.
  •  By evaluating IVDs with practical, real-world evidence, tests can better inform clinical decision making, policy, and ultimately patient outcomes.

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Saturday, March 28, 2026

Chris Klomp, Health Policy Expert for CMS and HHS - Some Notes on His Experience

Over the last few weeks, shake-ups at HHS have brought Chris Klomp to the #2 position next to Secretary Kennedy.  See news reports here; see an annotated one-hour interview with Klomp here.

I asked Chat GPT to discuss his educational background and professional experience through the lens of his current top-level health policy roles.

Endpoints discusses Klomp on AI, Klomp on biotech/China, Klomp on TrumpRx.

Friday, March 27, 2026

Korie et al. 2026: What Drives Next Gen Sequencing Denials at Yale Pathology?

Header:  A Yale pathology study presented at USCAP 2026 shows that NGS reimbursement denials are less about overuse and more about administrative failure—especially ICD-10 miscoding. Only 20% of cases were denied (275/1392), and most denials occurred despite guideline-concordant testing. The authors conclude, the fix is operational, not clinical.




Reimbursement Denials for NGS:
A Systems Problem, Not a Clinical One

[By Chat GPT 5.4]

At the March 2026 USCAP meeting, Korie et al. (Yale Pathology) presented a timely analysis of reimbursement denials for next-generation sequencing (NGS) in solid tumors:

Link (abstract PDF):
https://www.laboratoryinvestigation.org/action/showPdf?pii=S0023-6837%2825%2901936-1

The study evaluated 1,392 NGS tests performed between 2022–2023 at a large academic center. Of these, 275 cases (20%) were denied—a meaningful but not overwhelming fraction. That denominator matters: the system is not broadly failing, but the failures are highly patterned and correctable.

Register for AMA Meeting on Coding & AI: "Appendix S Revisions" - April 16

 AMA has big, big plans for changing how it handles AI services (potentially affecting digital pathology and genomics) in terms of policy and coding, possibly even with whole new classes of codes.  

These come under the headline of "Revising Appendix S," which has been a topic for several AMA CPT meetings in a row.   

You can register with AMA to view and comment on Appendix S plans, under the heading "Tab 67" of the next AMA CPT meeting.  Instructions here.  

New News: April 16:

AMA has just announced a special public meeting on Thursday April 16, from 430-600pm Central Time (530-700 ET, 230-400 PT).

Here's the AMA text and links.   Further below, I give you a very short AI summary of Appendix S.

See an essay from AMA policy participant Richard Frank MD - here