Wednesday, August 26, 2026

Piling on to Software as a service; MEDPAC Plans

 Everyone's piling onto Software as a Medical Service (SaMS), and related terms.  AMA CPT has been working on its Appendix S software coding paradigms.  CMS in July offered radical changes to come, beginning with a new acronym, SaMS.   Now the advisory body MEDPAC piles on.

Here's  how Google Gemini summarizes some new MEDPAC initiatives:

  • The MEDPAC agenda specifically highlights ongoing work to analyze Medicare’s payments for Software as a Medical Service (SaMD) and Prescription Digital Therapeutics (PDTs).
  • MedPAC breaks this digital health framework into two distinct buckets: 
    • SaMD / Software as a Service (SaaS): Algorithm-driven software designed to aid clinicians in diagnostic decisions or clinical assessments (e.g., AI image analysis, computational pathology, diagnostic algorithms).
    •  While Medicare has paid for some SaaS tools under fee schedules or inpatient new technology add-on payments (NTAP), MedPAC continues to question whether current relative values accurately reflect true costs.
  • Prescription Digital Therapeutics (PDTs): Patient-facing software applications delivered via personal devices to treat illness or injury. Because most PDTs do not fit into traditional Medicare benefit categories (like Durable Medical Equipment), coverage remains severely limited.
  • (MEDPAC is not using CMS's latest summer-2026 terminologies.)

See the MEDPAC agenda here:

https://www.medpac.gov/medpacs-analytic-agenda-for-the-2026-2027-meeting-cycle/


Revisited: CAP and CMS Go in Opposite Directions on Digital Pathology

In July rulemaking, in both OPPS (hospital outpatient) and Physician (aka Part B) proposed rules, CMS announced it will evict digital pathology / computational pathology services from CLIA services, and therefore strip them of their position on the Clinical Laboratory Fee Schedule.

Whether you love or hate CLIA, love or hat the CLFS, my reading of the SSA 1834A PAMA statute is that "clinical laboratory tests" go on the CLFS, and there is no mention of exceptions.  On the other hand, if a service is not a clinical laboratory service (the CL in CLIA), it can't go on the CLFS.

So, as far as I can tell, the only way CMS can reach its goal of tossing digital pathology out of CLFS, is to toss it out of CLIA.

But this is 180 degrees opposite CAP and CPT.  CAP and CPT are looking to have MORE CLIA requirements for computational pathology - copies of CLIA licenses, special letters from CLIA lab director to CPT, etc.  

On this theme, I asked Chat GPT if it could find documentation where CAP clearly places computational pathology under CLIA (and CAP-CLIA inspections, etc.

AI came back with alot.  If you want to comment to CMS, that computational pathology is a CLIA service, which CMS is directly denying, here are some bricks and stones you can throw.

This blog concludes with a model letter -- though too long -- to CMS about SaMS and CLIA and digital pathology.

Very Brief Blog: CMS OPPS CY2027 Comment Due Aug 31

There was a lot of action in summer rulemaking - both the OPPS and PFS (outpatient & physician part b) rules.

The deadline for comment on the OPPS policies is Monday, August 31.

Find it here:

https://www.federalregister.gov/documents/2026/07/07/2026-13656/medicare-program-hospital-outpatient-prospective-payment-and-ambulatory-surgical-center-payment


Broad actions include new policies for "Software as a Medical Service," and and classifying some current lab tests (often digital pathology) as SaMS and pulling them off the clin lab fee schedule.  

Basically, arguing that computational pathology tests are not laboratory tests.   

This is something where the AMA CPT is running full speed in the opposite direction - bringing those services under the scope of the CAP and Pathology Coding Caucus, requiring CLIA licenses for digital pathology, requiring lettetrs from the lab's CLIA director, etc.   

As usual, there's enough crazy to go around...


AI Reviews: ADAPT OR BECOME IRRELEVANT - Alternative Visions for Pathology

You may have seen it cited on Linked In - a new position paper on the future of pathology called, “Adapt or Become Irrelevant: The Pathologist as the New Diagnostic Architect.” 

It is co-authored by Mariano De Socarraz, MD, Founder and CEO of CorePlus, and Jochen K. Lennerz, MD PhD, Medical Director for Pathology Innovation at Natera.

See a Linked In article here.

See the original article here - subscription access.

And see this blog as an 11-page white paper here.


Here's a Chat GPT 5.6 mediated discussion.  Below, at 'Questions Arising," pretend I am sitting in the front row and the first to ask a hard-hitting question.

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50-word summary

Pathology must evolve from issuing isolated test results to architecting integrated diagnostic systems, De Socarraz and Lennerz argue. Across seven cases—PD-L1, NGS reimbursement, AI triage, integrated diagnostics, DPYD testing, trial design, and AI assurance—they call for pathologists to synthesize multimodal evidence, govern quality, shape workflows, and secure accountability.




The paper in review

In “Adapt or Become Irrelevant: the Pathologist as the New Diagnostic Architect”, Mariano De Socarraz and Jochen Lennerz offer a forceful manifesto for the future of pathology. Their central argument is not simply that pathology must adopt artificial intelligence, digital pathology, genomics, or other new technologies. It is that the profession must redefine its intellectual and organizational role.

Modern diagnosis increasingly draws on morphology, molecular testing, imaging, clinical history, therapeutic evidence, informatics, and computational outputs. Yet these components are generally produced and reported through separate workflows. The authors see a widening mismatch: diagnostic information has become multimodal and interconnected, while pathology remains organized around individual specimens, procedures, reports, and fee-schedule codes.

This is what they call a “cognitive crisis.” Pathologists are still too often treated—and sometimes treat themselves—as downstream interpreters who issue technically accurate reports but do not take responsibility for how the total diagnostic system fits together. The proposed alternative is the pathologist as “diagnostic architect”: the person who integrates multiple information streams into a coherent, clinically actionable account and helps design the structures through which that information is generated, validated, communicated, reimbursed, and used.

What Kind of Paper Is This?

Although labeled a review, the paper is better understood as a conceptual review or professional position essay. The authors combine selected literature, policy analysis, institutional experience, claims observations, qualitative interviews, and illustrative cases. They do not undertake a systematic review, present a reproducible dataset, or quantitatively compare competing models.

The authors acknowledge this. Their seven examples are intentionally heterogeneous and reflect their professional experience and institutional exposure. They describe the subjectivity as deliberate and say that the purpose is to provoke reflection and debate rather than establish a definitive consensus.

Its important contribution is therefore not a new empirical finding. It is a vocabulary and framework for describing where pathology might position itself within increasingly computational and multimodal medicine.

The Seven Diagnostic Scenarios

ScenarioProblem identifiedProposed pathology role
PD-L1 testingComplex, gradated biomarker reduced to a binary procedural resultIntegrate assay, specimen, scoring, biology, and therapeutic context
NGS reimbursementHigh denials and inadequate payment for interpretive and coordination workParticipate in payer policy, reimbursement design, and institutional planning
AI-based triageAutomation creates efficiency but can separate throughput from oversightGovern algorithms and redirect effort toward difficult cases and quality assurance
Integrated diagnosticsPathology, radiology, genomics, pharmacy, and oncology operate in silosBuild coordinated, disease-specific diagnostic pathways
DPYD testingProven pharmacogenomic intervention remains poorly implementedMove upstream from test performance to implementation leadership
Trial designTrials fail to use biomarkers for treatment adaptation and de-escalationEmbed pathology and biomarker strategy at trial inception
AI assuranceDiagnostic quality standards may be developed outside laboratory medicinePreserve pathology’s role in validation, monitoring, and accountability

1. PD-L1: From a Stain to a Contextual Biomarker

PD-L1 testing is the authors’ clearest example of how a technically valid test can lose clinical precision when it is operationalized as a procedural checkbox. PD-L1 expression is not a simple biological yes-or-no property. Its meaning depends on tumor type, drug indication, specimen selection, antibody clone, platform, scoring system, cutoff, immune-cell contribution, tumor heterogeneity, and preanalytic conditions.

The authors report substantial heterogeneity in test execution and scoring, even among institutions using the same antibody clone. Inadequate tissue, poor specimen selection, lack of clinical context, and unfamiliarity with tumor-specific scoring methods can weaken the relationship between the reported result and the likelihood of therapeutic benefit.

Companion-diagnostic approval formally ties a particular assay to a drug, but analytical validity does not ensure optimal clinical use. The pathologist’s role should therefore extend beyond correctly performing and scoring the assay. Pathologists should act as biomarker stewards, connecting the technical result to the biological and therapeutic context and preventing a complex biomarker from being flattened into a misleading binary output.

2. NGS Reimbursement: Diagnostic Complexity Without an Economic Model

Comprehensive genomic profiling illustrates the mismatch between the complexity of precision medicine and the procedure-based economics supporting it. The authors cite a Medicare NGS denial rate of approximately 23%, with denials reaching 37% in their own experience.

The problem is broader than the payment assigned to the sequencing procedure. Effective NGS use may require selecting appropriate tissue, assessing tumor content, integrating morphology and molecular findings, determining whether a variant is actionable, participating in tumor boards, supporting prior authorization, documenting medical necessity, and communicating treatment implications. Much of this cognitive and coordination work falls outside traditional fee-for-service payment.

The authors compare the physician work attached to molecular interpretation code G0452 with established evaluation-and-management and surgical-pathology codes. Their point is that conventional coding treats interpretation as a discrete, time-limited procedure, whereas modern molecular oncology requires ongoing synthesis and coordination.

Consequently, pathologists should participate in payer discussions, reimbursement design, coverage policy, and institutional planning. Precision oncology, they argue, cannot scale on an unstable financial infrastructure.

This is a notable expansion of the professional claim. The pathologist is no longer merely responsible for an accurate genomic report but also for helping make the service economically and operationally sustainable.

3. AI-Based Triage: Automation as Cognitive Redistribution

The authors use AI triage of prostate biopsies to argue that automation need not replace pathologists. In reported implementations, deep-learning systems identifying probably benign cores achieved negative predictive values exceeding 99%. This allowed pathologists to concentrate on suspicious, difficult, or clinically important cases while retaining final interpretive responsibility.

The envisioned benefit is not simply faster slide reading. It is a redistribution of professional effort:

  • Less time on repetitive, low-yield review.

  • More time on difficult interpretations.

  • More attention to quality assurance and discordant cases.

  • Responsibility for local validation and performance monitoring.

  • Oversight of model drift and lifecycle changes.

  • Participation in institutional AI governance.

Within the AMA taxonomy, this is augmentative rather than autonomous AI: the algorithm analyzes and prioritizes material, but the physician remains responsible for interpretation and reporting.

The authors’ larger point is that AI increases the need for pathology governance. An automated system deployed across thousands of cases may create more aggregate diagnostic risk than an individual human error. Someone must define acceptable performance, detect drift, investigate failures, and connect algorithmic output to clinical reality.


4. Integrated Diagnostics: From Parallel Reports to a Care Pathway

The authors broaden “integrated diagnostics” beyond combining pathology and radiology findings. They define it as aligning diagnostic information, professional authority, workflows, informatics, administration, and payer requirements around a patient-centered care pathway.

Current systems often produce fragmentation. Oncologists may order commercial molecular tests outside local pathology workflows. A pathologist may be unable to initiate reflex NGS even when the indication is evident. Specimens may be routed inefficiently, testing may be duplicated, and the clinical record may contain several technically correct but disconnected reports.

By contrast, disease-specific programs in which pathology, radiology, molecular diagnostics, oncology, pharmacy, and administration share governance can reduce redundancy and shorten time to treatment. The authors regard the pathologist as particularly well placed to connect these domains because pathology sits near the intersection of tissue, laboratory measurement, disease classification, and therapeutic biomarkers.

The intended endpoint is not merely a combined report. It is an integrated diagnostic strategy in which specimen use, test sequencing, information flow, clinical decisions, and payment requirements are designed together.

5. DPYD Testing: The Implementation Gap

DPYD genotyping identifies patients at elevated risk of severe or fatal toxicity from fluoropyrimidines such as 5-fluorouracil and capecitabine. The authors estimate that clinically important variants place approximately 3%–8% of patients at increased risk. Despite evidence of clinical utility and cost-effectiveness—and despite preventable deaths—routine testing has remained inconsistent.

The failure is not primarily analytical. It reflects fragmented ordering processes, inadequate reflex pathways, inconsistent reimbursement, limited clinician education, and the absence of infrastructure for preemptive pharmacogenomics.

This example supports an important distinction in the article: producing a valid test is not equivalent to producing clinical value. Pathologists should therefore help design the ordering, reporting, education, decision-support, and follow-up systems required to make a validated intervention routine.

6. Trial Design: Pathology Upstream, Not After the Fact

The authors use KEYNOTE-522 in early-stage triple-negative breast cancer to illustrate how successful trials may still impede individualized treatment. Although information such as tumor-infiltrating lymphocytes, PD-L1 expression, and early response was available, the trial did not use these markers to stratify therapy or test de-escalation. Patients received a prolonged regimen without a second randomization asking whether early responders needed continued adjuvant immunotherapy.

The authors see a structural commercial problem: biomarkers that expand a drug’s market are attractive to sponsors, while biomarkers that identify patients who can safely receive less treatment may not be. Consequently, potentially useful de-escalation strategies remain underdeveloped.

Pathologists generally do not control trial design, but they develop, validate, and interpret the biomarkers on which adaptive trials depend. The paper argues that they should be involved much earlier—in endpoint development, assay strategy, biomarker selection, and trial architecture—rather than receiving a nearly completed protocol and being asked to operationalize its laboratory component.

7. AI Assurance and “Assurance Displacement”

National AI-assurance initiatives create the paper’s most explicitly political concern. Organizations such as the Coalition for Health AI and proposed health AI assurance laboratories are developing methods for assessing safety, bias, transparency, and performance. These initiatives may be valuable, but much of their leadership and conceptual structure comes from outside pathology and laboratory medicine.

The authors introduce “assurance displacement risk”: the possibility that authority over diagnostic performance, bias management, model integration, and quality standards will migrate from pathology-led systems into external, algorithm-centered organizations.

Pathology has decades of experience with analytical validation, controls, proficiency testing, traceability, revalidation, postimplementation monitoring, and continuous quality improvement. The authors do not argue that pathologists should reject external AI governance. They argue that new frameworks should build upon this laboratory tradition and retain pathologists in standard-setting, clinical correlation, and lifecycle oversight.

Otherwise, pathology could become a consumer of standards created elsewhere rather than a steward of diagnostic quality.

The Proposed Professional Framework

The article distinguishes roles, competencies, and concepts.

The two principal roles are:

  • Diagnostic architect: Integrates morphology, molecular findings, imaging, and clinical information into a coherent, actionable assessment or care pathway.

  • Diagnostic steward: Assumes continuing responsibility for whether biomarkers, algorithms, and diagnostic workflows remain accurate and clinically appropriate over time.

The required competencies include:

  • Diagnostic synthesis.

  • Test-selection and utilization stewardship.

  • Institutional and policy leadership.

  • Systems thinking.

  • Digital and algorithmic fluency.

  • Strategic participation in reimbursement, regulation, and governance.

The broader concepts include integrated diagnostics, diagnostic governance, diagnostic intelligence, and assurance displacement risk. “Diagnostic intelligence” describes value that emerges only when multiple information sources are combined; it cannot be located in any single stain, sequence, image, or report.

The most consequential change is from episodic responsibility to lifecycle responsibility. The traditional pathologist signs out a case. The diagnostic steward is also concerned with how the test was selected, whether the algorithm remains calibrated, whether reporting promotes the right clinical action, whether unnecessary testing is occurring, and whether the system continues to perform after implementation.

The Kuhnian Claim

The authors invoke Thomas Kuhn to characterize the present moment as a paradigm crisis. Traditional pathology represents “normal science”: morphology as the principal ground truth, stable professional boundaries, location-based laboratories, siloed workflows, and incremental improvements in testing.

The seven cases are presented as anomalies that the traditional model can no longer comfortably absorb. Multimodal diagnosis, distributed testing, AI-based interpretation, external quality-assurance organizations, and value-based care require different forms of authority and collaboration. The new paradigm is therefore not simply digital pathology added to conventional pathology. It changes what counts as the professional product—from an accurate individual report to a coherent and accountable diagnostic system.

This is the article’s boldest claim. It is also the least empirically demonstrated. The authors establish that important changes are occurring, but whether these changes constitute a Kuhnian revolution rather than an enlargement of established consultation, laboratory-director, and quality-assurance functions remains debatable.

Strengths of the Article

The article succeeds in identifying a genuine structural problem: medicine produces increasingly sophisticated diagnostic components without reliably assigning responsibility for integrating them.

It is also persuasive in arguing that automation does not eliminate professional responsibility. AI may reduce routine review, but it creates new obligations involving validation, exception handling, performance monitoring, clinical correlation, and accountability.

Its vocabulary is useful. “Diagnostic architect,” “diagnostic steward,” and “assurance displacement” give names to functions that are real but frequently scattered across tumor boards, laboratory leadership, informatics committees, utilization programs, and informal consultations.

Finally, the paper connects clinical interpretation with economics and governance. A diagnostic technology can be scientifically excellent yet fail because ordering rules, reimbursement, specimen routing, reporting, or responsibility are incoherent.

Limitations and Unresolved Issues

The paper repeatedly says that pathologists are “uniquely positioned” to lead, but it does not rigorously compare pathology with oncology, radiology, clinical genetics, pharmacy, informatics, or multidisciplinary disease-management teams. Pathologists possess important expertise, but unique positioning does not automatically produce authority, time, training, or institutional resources.

Nor does the paper fully explain how the expanded work will be financed. It criticizes procedure-based reimbursement and shows that integrative work is underrecognized, but the proposed pathologist could simultaneously be a diagnostician, informatician, utilization manager, payer strategist, trial designer, quality officer, and AI governor. That is an attractive professional identity but not yet an operating or payment model.

The seven examples also represent different kinds of problems. PD-L1 concerns case-level interpretation; NGS reimbursement concerns economics; DPYD concerns implementation; KEYNOTE-522 concerns trial incentives; and AI assurance concerns institutional authority. Describing all seven as manifestations of one cognitive crisis is illuminating, but it may also impose unity on problems with quite different causes and solutions.

Questions Arising

BQ writes:

The central question I would put to the authors is this:

For complex biomarkers such as PD-L1, is each pathologist really making a separately obtained, de novo judgment—or primarily applying and transmitting the best available state-of-the-field knowledge, of the kind represented by UpToDate, CAP/IASLC guidance, etc? 

If much of the work is disciplined application of recently curated knowledge, is this truly a transformation of the pathologist’s role or a new, unexpected kind of role?

Does it boil down to, the pathologist and oncologist need to check UpToDate every quarter?

The Case for This Skeptical Position

Your challenge identifies a real inflation in the paper’s rhetoric. High-quality biomarker interpretation should not depend on every pathologist independently reinventing the meaning of PD-L1. The objective is precisely to reduce idiosyncratic judgment through validated assays, standardized scoring systems, indication-specific cutoffs, guidelines, proficiency testing, and decision support.

Much of what the authors describe as “diagnostic intelligence” may consist of three relatively conventional activities:

  1. Keeping current with published evidence and regulatory changes.

  2. Applying standardized rules correctly to an individual specimen.

  3. Communicating the result in a form that an oncologist can use.

If those activities can be encoded in protocols, report templates, reflex algorithms, and regularly updated knowledge systems, then the profession may need better information management rather than a new professional identity.

The article also sometimes conflates possessing knowledge with leading an entire system. Knowing that PD-L1 scoring varies by tumor and indication does not necessarily make the pathologist the natural leader of reimbursement policy, trial design, pharmacy integration, or the patient’s total treatment strategy. In some settings, a specialized oncologist, molecular tumor board, clinical pharmacologist, or informatics team may be better positioned.

“Check UpToDate every quarter” is therefore a pointed way of asking whether the paper has converted the ordinary professional duty to remain current into a supposed Kuhnian revolution.

The Case for the Authors

The strongest response is that curated knowledge cannot examine the actual tissue. UpToDate can describe which scoring system applies, but it cannot determine whether the available block is representative, recognize heterogeneous staining, distinguish tumor cells from immune cells, assess fixation artifacts, reconcile a discordant molecular result, or determine whether the assay has been locally validated for that specimen type.

Nor is the relevant knowledge contained in one source. PD-L1 interpretation may require the FDA label, tumor-specific guidelines, assay instructions, pathology standards, clinical-trial criteria, local validation data, and knowledge of the specimen’s history. A quarterly literature check may establish the general rule but does not apply it to the peculiarities of an individual patient and specimen.

The authors’ strongest argument is also not about possessing facts. It is about responsibility for the interfaces between facts. Someone must notice when:

  • The wrong specimen was selected.

  • The tissue is inadequate or unrepresentative.

  • Different PD-L1 assays or scoring systems are being treated as interchangeable.

  • PD-L1, tumor mutational burden, microsatellite instability, morphology, and clinical history point in different directions.

  • A commercial test bypasses local specimen-management safeguards.

  • A validated biomarker is never ordered because the workflow has no trigger.

  • An AI model’s performance deteriorates after deployment.

  • A technically correct report predictably produces the wrong clinical interpretation.

No quarterly update can by itself establish ownership of those failures. The authors are arguing that pathology should claim this integrative and governance responsibility before it is assigned elsewhere.

What's the AI Assessment

The paper is most persuasive if three different activities are kept separate:

  • Knowledge maintenance: Keeping guidelines, protocols, and decision support current. This is essential but not transformational.

  • Patient-specific interpretation: Applying standardized knowledge to a particular specimen and clinical setting. This involves genuine judgment, but it is an extension of traditional pathology.

  • Systems architecture and lifecycle governance: Designing reflex pathways, integrating modalities, governing algorithms, resolving responsibility, and monitoring performance over time. This is the truly expanded role.

Thus, your criticism lands against the paper’s occasional tendency to describe all sophisticated application of knowledge as a cognitive revolution. Every PD-L1 case should not become an act of solitary intellectual creation. Standardization and curated knowledge are virtues, not threats to professional status.

But “check UpToDate every quarter” is insufficient because the hard part often lies in local implementation, specimen-specific exceptions, cross-modal discordance, and accountability. UpToDate can supply the map; it cannot determine whether the patient, specimen, assay, local workflow, and reported conclusion are actually traveling along the right road.

The fairest conclusion is that the transformational element is not that the pathologist knows something the oncologist could never look up. It is that the pathologist accepts responsibility for making standardized knowledge work reliably in a particular patient and across an entire diagnostic system. The article is strongest when it makes that systems-governance claim—and weakest when it presents ordinary expert interpretation itself as a new paradigm.



Tuesday, August 25, 2026

AI Guest Author: Waiting for CRUSH Regulations from OMB

 

CRUSH at OMB: The Next Stage of a Twenty-Year Medicare Anti-Fraud Campaign

AI Corner: Chat GPT 5.6; 8-25-2026

The next major Medicare and Medicaid program-integrity proposal is now under review at the Office of Management and Budget. OMB’s public record shows that it received the proposed Comprehensive Regulations to Uncover Suspicious Healthcare, or CRUSH, rule from CMS on August 7, 2026. The OMB listing does not reveal the proposed text or establish a publication date, but it confirms that CRUSH has advanced beyond the preliminary information-gathering stage.

CMS previewed its thinking in a February 2026 request for information on CRUSH (91 FR 9803). That document asked about a strikingly broad range of possible policies. These included faster payment suspensions, stronger enrollment and revocation authority, expanded identity and ownership verification, greater use of prepayment review and data analytics, and new controls for Medicare Advantage, Part D, Medicaid, laboratory testing and durable medical equipment.

The eventual proposal may not include every idea raised in the request. Nevertheless, several possible directions are apparent:

  • CMS could make it easier to deny, deactivate or revoke the enrollment of providers and suppliers considered high risk.

  • Payment suspensions and prepayment review could be expanded, including possible requirements for Medicare Advantage and Part D plans to stop payments at CMS’s direction.

  • Owners, managers and affiliated entities could face additional identity proofing, fingerprinting, background checks and disclosure requirements.

  • CMS could tighten claim-filing deadlines, surety-bond requirements and restrictions on beneficiary solicitation.

  • Laboratories—particularly those performing genetic and molecular testing—could potentially receive targeted new oversight,

(OIG to look at genetic tests 2027 here.  CMS looks to strangle huge payments under code 87798 here. Earlier, I called 81408 the "fraudomatic" genetic code, at $4000/patient, here.)

Sunday, August 23, 2026

CRUSH Reaches White House / OMB, Who Will Release the Proposed Regulations

 

NEWS: CMS Sends Major CRUSH Anti-Fraud Rule to OMB

The February request for information has quietly become an actual proposed rule, with new Medicare enrollment and enforcement provisions potentially only weeks away.

A major anti-fraud regulatory proposal is on the desk of management officials at the White House Office of Management and Budget, awaiting signoff for publication.

CMS transmitted its proposed Comprehensive Regulations to Uncover Suspicious Healthcare—better known as CRUSH—to OMB on August 7, 2026. The proposal remains under review by OMB’s Office of Information and Regulatory Affairs. It is officially classified as a proposed rule, not a final rule, and is not designated economically significant. The OMB regulatory-review page is here.

Saturday, August 22, 2026

Blog 5 of 5: AI Rewrites My Human Blog #3 (88305 Super-Providers)

In this series of 5 blogs, Blog 3 (national and super-provider utilization) was written by Quinn by hand.  Here is  Blog 3, rewritten from source material entirely by Chat GPT 5.6.

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88305: Blog 5 of 5 — What Medicare’s Biggest Users Tell Us About the 25-Minute Problem

The developing Medicare controversy over CPT 88305 can be approached from two directions. The Maryland Health Care Commission approached it at the level of the provider-day: multiply the number of 88305 services billed by Medicare’s assigned physician time, and ask whether the resulting workload can fit into an actual day. Sometimes it cannot. Maryland found hundreds of days on which 88305 alone translated into more than 24 hours of nominal physician work.

There is another way to look at the same issue. Instead of studying individual days in Maryland, one can pull back and examine an entire year of national Medicare utilization. CMS’s CY2024 Medicare Physician & Other Practitioners — by Provider and Service public-use file offers exactly that perspective. Filtering the enormous database to a single code, 88305, reveals both the scale of the business and some remarkable concentrations of utilization.

The national data cannot determine how many minutes a pathologist actually spent on a particular slide. Nor should they be treated as if they could. But as a broad reality check on the longstanding assumption that a typical 88305 contains 25 minutes of pathologist intraservice work, they are unusually provocative.

Blog 4 of 5; We Discover the Source of the CMS 88305 Data: Mesta et al., June 2026!


50-word summary

CMS’s July 2026 CY2027 Physician Fee Schedule proposal reproduced striking Maryland data suggesting CPT 88305 may be overvalued -- without naming the source. 

Discoveries in Health Policy has discovered that the trail leads to Maryland Health Care Commission officials Mesta, Chappel, and Jacobs in Health Affairs

Their open-access article adds useful detail—and methodological questions that pathologists will find worth raising now.

Friday, August 21, 2026

88305: Blog 3 of 5: National and Busy-Individual Usage for 88305 in Medicare Part B

In summer rulemaking, CMS proposed surgical biopsy billion-dollar-code 88305 as a mispriced code.  Blog #1 here.    I also had Chat GPT research the policy history of the odd surg path coding system (it took 26 minutes!).  Blog #2 here.

In this third blog, I look at provider-by-provider Medicare Part B data for 88305.  (I got the 88305 data from  here.  It's CY2024.)

Note; See the same scope of data reviewed and written solely by AI - Blog 5 here.

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17,430 different providers were paid for 88305.   $931M.

576 were Clinical Laboratories, paid $226M or about 20% of all dollars.  All the other dollars went to entities enrolled as providers (pathologists, dermatologists, etc.)

13,680 rows were pathologists.  1719 were dermatologists.  904 were gastroenterologists.  Just 33 were urologists (Medicare pays for prostate biopsies as a blanket lab fee, not per core).

Thursday, August 20, 2026

FDA Approves De Novo Software that Makes Diagnosis on Brain MRI: NeuroPacs

August 7, we published a blog on software diagnosis in radiology and asked how fast it might come to pathology.   Here.  And we've already updated that once, August 14.  Here.

Below, FDA approves de novo software that auto classifies MRIs as Parkinson disease vs several other disorders.  Brave new world.

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AI Corner

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A few weeks ago, this blog reviewed DeepHealth SMART-B, an FDA-cleared breast-ultrasound system that detects and characterizes lesions and generates draft findings and impressions for radiologist review. That clearance prompted a broader discussion of the outlook for report generation in pathology—already visible in several U.S. research-use-only products and in some software cleared for clinical use in Europe.

Here is another timely example from a different corner of diagnostic medicine. FDA has granted De Novo classification to neuropacs, machine-learning software that analyzes diffusion MRI and produces a diagnostic classification report for Parkinson disease and two related parkinsonian disorders.

88305: Blog 2 of 5: The Ancient History of Surg Path Coding (88305 1960s?)

Here's a challenge I gave to Chat GPT 5.6.  What's the origin of the coding system for surgical pathology - biopsies 88305, etc.   CPT produces Surg Path Levels "I" to "VI," scattered between 88300 and 88309.

The levels are different than Tier II genetic procedure levels, where one is to use a level ("I" to "IX") only if your specific gene is named there.  For Surg Path levels, CPT says use the level that is the closest match to the specimen you examined.

But where did this system come from?  Does anybody know?  Chat GPT thought for a remarkable 26 minutes before printing the answer below.

(I also asked Claude Opus, which answer was directionally similar but less detailed).

(See an article on CMS proposed revaluation of 88305 here.)

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The short answer is: the recognizable surgical-pathology ladder—88300, 88302, 88304, 88305, 88307 and 88309—is securely documented in the fourth edition of CPT in 1977

Wednesday, August 19, 2026

88305: Blog 1 of 5: CMS Proposes Review of Code 88305. Chat GPT Writes White Paper Report.

 In July, when CMS released the proposed policies for physician fee schedule aka Part B, it included a proposal to review the valuation of code 88305, one of the most frequently used pathology codes.  The proposal came over the transom from State of Maryland.

  • Below, summaries of a white paper report written by Chat GPT on the topic.  
  • Find the 20-page AI report HERE.





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50-Word Summary

CMS’s 2026 scrutiny of CPT 88305 challenges a 25-minute pathologist time assumption re-surveyed and affirmed by the RUC in 2010. Maryland claims data suggest that assumption can produce impossible workdays. Historical radiology and pathology practice-expense resets show Medicare has previously rebased payment when older resource models no longer matched practice.

Tuesday, August 18, 2026

Chat GPT Reviews History of McDermott Plus Consulting - After News from Politico

We're waiting for confirmation of a news item in Politico that McDermott Plus is closing in August 2026.

While we wait, Chat GPT ran a internet search for information about the history of the firm.  This article is AI-written.  It can be used as an example of current AI ability to understand a task, do research, organize it, and write it up.  It should not be taken as ground truth.

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McDermott+: A 12-Year Experiment in Health Policy, Reimbursement and Washington Advocacy

On August 18, Politico reported that McDermott+, the health policy consulting and lobbying organization affiliated with McDermott Will & Schulte, will close at the end of August, with dozens of employees entering the Washington job market. Assuming the report is correct, the closure will bring to an end a distinctive 12-year experiment in combining health policy consulting, reimbursement strategy, data analytics and conventional Washington lobbying under one roof.

For many people in health policy, McDermott+ was sufficiently familiar that its unusual corporate structure could be easy to overlook. It looked and sounded like part of the McDermott law firm, occupied the same Washington address, shared personnel and frequently worked alongside McDermott lawyers. But it was not a law practice.

A deliberate spinout — but never an independent one

McDermott Will & Emery formally launched McDermott+Consulting, or McDermottPlus, in April 2014. The announcement described it as a “separate and distinct, wholly-owned subsidiary” of the law firm. Its original menu was unusually broad: 

  • congressional and executive-branch lobbying, 
  • budget-impact and cost-effectiveness modeling, 
  • political communications, 
  • public- and private-payer coverage, coding and pricing strategy, and 
  • healthcare data analysis. 
  • The firm explicitly promoted the ability to use project fees and retainers rather than limiting engagements to traditional law-firm hourly billing to the tenth of the hour. (KSL)

Thus, McDermott+ was less a conventional corporate spinout than a closely held consulting affiliate. That distinction remained important. McDermott’s current legal notices state explicitly that McDermottPlus LLC is wholly owned by McDermott Will & Schulte and does not provide legal advice or legal services. (McDermott) Earlier McDermott+ publications similarly cautioned that communications with the consulting company did not carry attorney-client privilege.

The arrangement nevertheless allowed extremely close integration. A client could be working with McDermott+ consultants on reimbursement economics, CMS policy or lobbying and, when a question required legal analysis, bring in lawyers from the parent firm. A later McDermott case study on Medicare coverage of over-the-counter COVID-19 tests describes exactly that sequence: McDermott+ organized and advocated for a coalition, then drew on McDermott lawyers to develop the legal theory supporting a potential CMS coverage pathway. (McDermott)

The practice existed before the name

The intellectual roots of McDermott+ predated the 2014 corporate launch.

McDermott already had a prominent Washington health-policy and reimbursement practice spanning Medicare payment, coverage, coding, FDA regulation and congressional advocacy. Paul Radensky, MD, JD, and Eric Zimmerman were conspicuous participants in that world. For example, both appeared on the agenda of CMS's 2013 annual Clinical Laboratory Fee Schedule meeting, with Zimmerman representing McDermott and the Coalition for 21st Century Medicine and Radensky appearing for McDermott separately. (Centers for Medicare & Medicaid Services)

The creation of McDermott+ essentially gave that kind of work a larger nonlegal platform.

At the 2014 launch, Radensky and Zimmerman were both identified as principals. Zimmerman said the objective was a “one-stop shop” combining lobbying, analytics and policy work; Radensky emphasized the growing need for quantitative analysis and for strategies that could move new technologies through complex government regulatory and payment systems. (KSL)

Zimmerman was later explicitly described by McDermott+ as a co-founder. (McDermott+)

Paul Radensky and the reimbursement side of McDermott+

For many in the diagnostics, medical-device and biotechnology communities, however, Paul Radensky became one of the people most closely identified with McDermott+.

His background was unusual even by Washington health-policy standards: an MD from the University of Pennsylvania, internal-medicine training and a fellowship in liver disease, followed by a Harvard JD. His practice joined regulatory law to the highly specialized mechanics of obtaining Medicare coverage, coding and payment for new medical technologies. McDermott credits him with work leading to national and local Medicare coverage decisions, Coverage with Evidence Development protocols and reimbursement strategies for pharmaceuticals, biologics, devices and clinical laboratory technologies. (McDermott)

That expertise helped give McDermott+ a character different from that of a general K Street shop. A client might arrive not because a bill was moving through Congress but because a diagnostic needed a coding pathway, a medical device faced an unfavorable Medicare payment methodology, a laboratory test needed a coverage strategy, or a manufacturer needed to understand the interaction among FDA status, Medicare benefit categories, CPT or HCPCS coding and CMS payment rules.

Radensky was particularly visible in diagnostics. McDermott+ work during the period included laboratory payment policy under PAMA, advanced diagnostics, medical devices, drug reimbursement and Medicare coverage. His representative activities also included the Coalition for 21st Century Medicine and coalitions involving diabetes testing and other diagnostic technologies. (McDermott+)

Radensky subsequently stepped back from his former partner status. McDermott's current website lists him as Counsel, while still stating that he serves as a principal of McDermott+; the McDermott+ site also continued to list him among its professionals in August 2026. (McDermott) In other words, the public record suggests a gradual change in role rather than a disappearance from the organization.

From reimbursement boutique to broader health-policy operation

McDermott+ also expanded well beyond the product-reimbursement work for which Radensky was known.

By 2018, four years after its founding, the firm said it had grown to ten consultants and had deliberately recruited former executive-branch officials, congressional staff and experienced policy consultants. That year it added Mara McDermott, formerly a senior federal-affairs executive for America’s Physician Groups, and Rachel Stauffer, who had worked on Capitol Hill and in the Office of the National Coordinator for Health IT. (McDermott+)

Over time, the roster became a recognizable cross-section of Washington healthcare expertise. Debbie Curtis brought 24 years of congressional experience, including work for Rep. Pete Stark and the House Ways and Means Health Subcommittee. Rodney Whitlock had worked for Rep. Charlie Norwood, Sen. Chuck Grassley and the Senate Finance Committee. Jeffrey Davis had spent eight years at HHS before working at the American College of Emergency Physicians. (McDermott+)

Others brought expertise in Medicare Advantage, Medicaid, hospital prospective payment systems, medical devices, health economics, CMMI models and claims-data analysis. By August 2026, the public professional roster included roughly two dozen names spanning policy, lobbying, reimbursement and analytics. (McDermott+)

The resulting organization could operate at several levels of the healthcare-policy system simultaneously.

For manufacturers, McDermott+ offered product-level market-access work involving coverage, coding and payment. For hospitals and health systems, it worked on Medicare payment systems, rural-hospital policy and broader federal reimbursement issues. For plans and other organizations, it developed expertise in Medicare Advantage and Part D. For provider organizations and investors in delivery-system reform, it became active in accountable care and CMMI payment models. And for associations, coalitions and corporations, it offered traditional congressional and agency advocacy.

That breadth became the firm's defining proposition. Its website in August 2026 still described McDermott+ as combining consulting, policy and lobbying with data analytics and specialized knowledge of reimbursement, coding, coverage and quality reporting. (McDermott+)

A lobbying shop, but not only a lobbying shop

McDermott+ nevertheless became a substantial registered federal lobbying operation.

One recent academic analysis using OpenSecrets data found that McDermott+ reported about $4.39 million in federal lobbying revenue from 33 clients in 2024. Of that amount, approximately $1.11 million came from seven hospital-industry clients, placing McDermott+ among the larger firms lobbying for hospitals that year. Those figures capture disclosed lobbying revenue, not the company's separate consulting, analytics or reimbursement-strategy business. (JAMA Network)

Its work also illustrates how lobbying could be combined with technical policy expertise. McDermott+ represented hospital coalitions, technology companies, diagnostics firms and other healthcare interests before Congress and executive agencies. Zimmerman, for example, has served as Washington representative for Trinity Health, rural-hospital coalitions, diabetes-testing interests and the Coalition for 21st Century Medicine. (McDermott+)

Coalitions became another recurring feature of the model. During the COVID-19 pandemic, Radensky and Zimmerman led an effort bringing together five competing suppliers of at-home testing products to seek Medicare coverage. In another case, a McDermott+ team worked with a coalition of more than 25 organizations around Medicare direct contracting and what became the ACO REACH model. (McDermott)

Those engagements captured what McDermott+ could do that a reimbursement boutique, analytics shop or lobbying firm alone might have found harder: combine the technical policy argument, its economic implications, stakeholder organization and the Washington campaign required to move it.

It also became a health-policy publisher

A quieter part of the McDermott+ story was its development into a significant public-facing source of health-policy information.

The McDermottPlus Check-Up began providing regular Washington health-policy summaries by 2019. The organization added the Health Policy Breakroom podcast, regulatory commentary, election and policy previews, Medicare data tools and interactive dashboards. By 2026, its website included dedicated products for Medicare data analytics, NTAP strategy, Medicare Advantage and Part D, physician and hospital payment dashboards and a premium information service called McDermott+ Insider. (McDermott+)

In April 2024, co-founder Eric Zimmerman appeared on the Health Policy Breakroom specifically to mark McDermott+'s tenth anniversary and discuss its first decade. (McDermott+)

The public-content operation mattered partly because it kept McDermott+ visible well beyond its paying clients. Hospital executives, laboratory-policy specialists, trade-association staff, Washington lawyers and reimbursement consultants routinely encountered its summaries of proposed and final CMS rules even if they were not currently working with the firm.

That makes the reported shutdown unusually conspicuous. As recently as August 7, 2026, the McDermott+ website was still publishing its weekly Check-Up, and in early August it had posted analyses of the FY 2027 inpatient final rule and other major Medicare regulations. (McDermott+)

A changing parent organization

The closure also occurs against a changed backdrop at the parent law firm.

McDermott Will & Emery merged with New York-based Schulte Roth & Zabel effective August 1, 2025, creating McDermott Will & Schulte, a firm of roughly 1,750 lawyers across more than 20 offices. McDermott brought particular strength in healthcare, while Schulte was especially known for private capital and investment-fund work. (Reuters)

There is not yet enough public information to attribute the reported McDermott+ closure to that merger or any other factor.  The parent firm continues to maintain a major healthcare practice, and several McDermott+ principals have simultaneously held roles at the law firm.

An unusual niche in Washington healthcare

McDermott+ lasted from the early years of Affordable Care Act implementation through MACRA and alternative payment models, PAMA laboratory reform, Medicare Advantage expansion, COVID-19 emergency policy, the Inflation Reduction Act and another major shift in federal health policy after the 2024 election.

Its enduring distinction was not any single one of those subjects. It was the attempt to place several professions that normally sit beside one another — health lawyers, former Hill staff, CMS and HHS veterans, reimbursement specialists, clinicians, lobbyists, economists and data analysts — inside one small organization.

For some clients, McDermott+ was essentially a Washington lobbying firm. For others, it was a Medicare reimbursement consultancy. For still others, it was a source of payment modeling, policy intelligence, coding strategy or coalition management.

And because the organization remained wholly owned by one of the country's best-known healthcare law firms, it occupied an unusual space between Big Law and K Street without being quite either one.

If the reported August 2026 shutdown proceeds as described, that hybrid organization will disappear. Much of its expertise almost certainly will not. In Washington health policy, where former agency officials, congressional staff, lawyers and consultants regularly reassemble in new combinations, the more consequential story may be where the McDermott+ people — and the functions they performed — turn up next.


Sunday, August 16, 2026

New Proposal Introduces Broader Authority for Political Input to NIH Grant Decisions

Back in May 2026, OMB issued a proposed rule that would lay out the authority and framework for political appointees to have a much stronger hand in grant approval decisions.  See article by AP here.  AP also linked back to a Executive Order on the topic back in August 2025 - here.  It might reduce the chance the political grant cuts would get contested in court as happened when grants were abruptly defunded around March-April 2025 (here).  

  • See 108pp OMB proposal here; comment ran to July 13.
  • The OMB policy stated in part:
  • Although Federal spending through grants and other types of Federal financial assistance has grown exponentially since the initial establishment of OMB's policies in earlier Circulars and 2 CFR, corresponding policies capable of ensuring transparency, accountability, and oversight for this increased level of spending remain deficient in the current regulatory text. As a result, Federal programs, and the activities performed under Federal awards, have not always remained properly aligned with core purposes authorized by law, nor served the needs of the American public as intended.
  • This lack of transparency, accountability, and proper oversight became increasingly clear between 2021 and 2024. Federal awards were often used during those years to promote a “woke” policy agenda that did not reflect the values of the vast majority of the American public...

Here comes what may be a related document in the set, from NIH, about presentation of data from NIH grant reviews - here.  Dated August 14, 2026. It's titled, Request for Information (RFI) on Proposed Changes to Reporting Outcomes from NIH Peer Review, Notice Number: NOT-OD-26-088.  Issued 8/14, your comments due 10/13.



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I'll let Chat GPT discuss the details.

See also a ten-page AI generated white paper on this topic  >>>  here   <<< .

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NIH has issued something notable. And it fits almost hand-in-glove with the OMB proposal from May 2026, although the NIH notice here is itself framed as a technical reform intended to reduce false precision in peer-review scoring.

The chronology makes the architecture clearer. In November 2025, NIH adopted its Unified Funding Strategy, effective with the January 2026 Council round, expressly moving away from rigid paylines and toward decisions that balance peer review with health priorities, scientific opportunities, workforce considerations, portfolio balance, and available funds. (Grants.gov

Then on May 29, 2026, OMB proposed its government-wide rule requiring senior appointees to independently review discretionary awards rather than routinely defer to peer-review recommendations. (Federal Register); 108pp.  Comments closed. 

Now: on August 14, NIH proposes to remove the principal quantitative output of peer review from everybody downstream of the study section. (Grants.gov)

That last point is more substantial than the headline suggests.

  • Today, an R01 might emerge from study section with, say, an impact score of 18 and 2nd percentile. The PI sees it. Program sees it. Institute leadership sees it. Council sees it. Everybody knows that this was an exceptionally highly ranked application.
  • Under the proposal, the reviewers would still score it numerically, and NIH would still calculate the final impact score behind the curtain—but the PI, institution, program staff, ICO leadership and Advisory Council would not receive either that score or the percentile. They would be told merely:

CurrentProposed
Impact score 18, 2nd percentileMost competitive
Impact score 27, 23rd percentileMost competitive
Impact score 31, 28th percentileCompetitive
Below discussion thresholdNot discussed

The first two applications therefore become formally indistinguishable in the information delivered to the people making the funding decision—even though the study section may have regarded one as markedly stronger. 

NIH says this is intentional: exact scores have “imperfect discriminative ability,” and removing them will cause program officials to pay greater attention to critiques and exercise judgment about NIH priorities and portfolio considerations. (Grants.gov)

There are really two stories here

One is a perfectly respectable science-of-peer-review argument. A score of 18 versus 21 isn't a laboratory measurement. Reviewer composition, study-section dynamics and random variation matter; the literature has long questioned whether tiny score differences justify cliff-edge funding decisions. NIH's argument is basically: stop pretending a noisy ordinal judgment is a micrometer. That's defensible, and NIH specifically says that critiques, criterion scores, discussion summaries, and the actual peer-review process remain. (Grants.gov)

But the second story is governance.

NIH isn't merely saying, “Don't fetishize the score.” It proposes to withhold the score altogether from program officials, Institute directors, Advisory Councils, applicants and institutions. That substantially reduces the externally visible constraint imposed by peer review. The old system made departures from review rank conspicuous: Why was a 3rd-percentile application passed over while an 18th-percentile application was funded? Under the proposed system, both may simply read MOST COMPETITIVE.

And that intersects remarkably with the Unified Funding Strategy. NIH already says ICOs should no longer use paylines and should instead integrate scientific merit with institutional priorities, health priorities, workforce, portfolio and financial considerations. (Grants.gov) The new proposal removes much of the numerical information that could constrain—or at least make visible—how far those discretionary decisions depart from study-section ranking.

Then put the OMB May 29 proposal next to it. OMB's proposed government-wide regulation says senior appointees should exercise independent judgment rather than routinely defer to recommendations and explicitly makes peer-review recommendations advisory. (Federal Register)

So I would distinguish intent from institutional effect. The NIH RFI does not say, “We want political appointees overriding scientists,” and it would be overstating the document to describe it that way. But institutionally, the sequence is striking:

  • November 2025: abolish dependence on paylines →
  • May 2026 OMB: emphasize independent judgment of political leadership over discretionary grants →
  • August 2026 NIH: collapse peer-review results into three broad categories and conceal exact scores from downstream decision-makers.

That combination transfers information and discretion away from an easily auditable numerical peer-review ranking and toward programmatic/leadership judgment.

One additional detail caught my eye [writes Chat GPT]: NIH released NOT-OD-26-088 on Friday, August 14—the same day NIH held its previously scheduled public webinar, “Understanding NIH's Unified Funding Strategy: What the Research Community Needs to Know.” (Grants.gov) So this appears less like an isolated CSR housekeeping proposal than another deliberate step in implementing the Unified Funding Strategy.

And there's a terrific blog headline hiding in the mechanics:

NIH Peer Review: The Score Will Still Exist. You Just Won't Be Allowed to See It.

The RFI comment deadline is October 13, 2026. (Grants.gov)

This is considerably more interesting when framed as the third act of the 2025–26 story—Unified Funding Strategy → OMB grant rule → NIH score suppression—rather than as a standalone item that “NIH changes peer review details.” 

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A negative reaction to the NIH RFI - here.

Why CMS MAC Questions for Synuclein Diagnostics Miss the Main Point

This week, on August 20, several Medicare MACs will hold a public session on the literature on alpha-synuclein tesitng for Parkinson's and related disorders (synucleinopathies).  

It's an important opportunity for the neurologic community as most physicians get very little training in neurology.  I suspect as few as ten percent take a full elective month in neurology (they only get a few electives) and once they're off in residency track (surgery, ER, pediatrics, immunology, etc) neurology is far in the rear view mirror. [*]

Questions for the advisory meeting have been posted:

 https://med.noridianmedicare.com/web/jeb/policies/lcd/cac/cac-questions-biomarkers-utilized-in-the-diagnosis-of-synucleinopathies-key-question

While there may be too many questions, and some are repetitive, they seem to question whether diagnostics matter at all in neurology.  Whether diagnosis affects management would usually be out of scope of a specific diagnostic study, and here, there is not one outcome (like "survival" in cancer) but diverse ones across the diverse presentation of disease.   The most important metric for Patient A may be a symptom patient B doesn't even have.

Parkinson's itself has protean symptoms - what other disorder causes both visual hallucinations and foot cramps?  And in between there's swallowing disorders, gastroparesis, orthostatic hypotension, constipation, bladder disorders, balance disorder with falls, restless leg syndrome, insomnia (sometimes to a toxic degree), and others.   In this sense, Parkinson's has protean entry points and outputs, like lupus.

Here's some clarification from Chat GPT:

“Protean” disease is a familiar medical concept, not an argument against the importance of diagnosis. In several classic disorders, the underlying disease is critical to figure out, precisely because a patient may enter the healthcare system through very different symptoms and may require management across multiple organ systems.

Six useful comparators:

  1. Syphilis — the archetypal “great imitator.” Depending on stage and site, it can present with dermatologic, neurologic, psychiatric, ocular, auditory, and cardiovascular disease; neurosyphilis itself ranges from meningitis and cranial neuropathies to stroke, tabes dorsalis, and general paresis. (CDC)

  2. Systemic Lupus erythematosus. One patient may present with arthritis or rash, another with nephritis, cytopenias, seizures or cognitive problems, pleuritis, pericarditis, or vasculitis. NIH explicitly notes that manifestations vary greatly among individuals and can change over time. (NIAMS)

  3. Sarcoidosis. Usually thought of as pulmonary disease, but it can involve lymph nodes, skin, eyes, heart, liver, salivary glands, and the nervous system. Thus two patients with the same underlying granulomatous disease can look almost unrelated clinically. (NHLBI, NIH)

  4. Systemic vasculitis — particularly ANCA-associated disease. Depending on which vessels are involved, presentation can be sinus disease, pulmonary hemorrhage, renal disease, rash, neuropathy/foot drop, eye disease, constitutional symptoms, or gastrointestinal involvement. The very diversity of manifestations makes establishing the unifying diagnosis especially consequential. (MedlinePlus)

  5. Systemic amyloidosis. The same protein-deposition process can manifest as cardiomyopathy, nephrotic renal disease, peripheral or autonomic neuropathy, hypotension, gastrointestinal dysfunction, hepatic disease, carpal tunnel syndrome, or combinations of these. NIDDK specifically emphasizes that different patients have different organs and tissues involved. (NIDDK)

  6. Multiple sclerosis — a particularly useful neurologic analogy. Although confined principally to the CNS rather than being truly systemic, its clinical expression is extraordinarily heterogeneous: optic/visual disease, sensory symptoms, weakness, spasticity, gait and balance problems, pain, cognitive problems, fatigue, and bowel/bladder dysfunction can appear in different combinations and at different points in the disease course. (MedlinePlus)

The analogy to Parkinson's is quite strong. The Australian “iceberg” (pic below) is not simply an advocacy graphic making Parkinson's look complicated. It reflects the fact that PD will simultaneously be a movement disorder, autonomic disorder, sleep disorder, gastrointestinal disorder, neuropsychiatric disorder, cognitive disorder, and bulbar disorder. Hallucinations and foot dystonia [cramps] may indeed belong to the same disease as gastroparesis, orthostatic hypotension, RBD, urinary dysfunction, sudden falls, dysphagia, constipation, and bradykinesia.



That matters directly the somewhat odd premise running through the MAC  questions. MACs acknowledge that synucleinopathies encompass “multiple diseases and a broad array of signs and symptoms,” yet repeatedly asks what useful outcome, if any, could follow diagnosis in the absence of curative (disease-modifying0 therapy.  (And a trial could only pick one or two definitive endpoints; for synuclein diagnostics in early patients, surely that can't be 20-year survival).

In a protean progressive disease, heterogeneity is a powerful reason why diagnosis matters: identifying the unifying disease organizes otherwise disconnected symptoms, directs surveillance, anticipates complications, informs medication and referral choices, and gives meaning to new manifestations as they emerge.

Syphilis, lupus, sarcoidosis, vasculitis, amyloidosis—and PD—would all be vastly harder to manage if medicine insisted that "diagnosis had little value" until there was a curative treatment.

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[*] I have some content knowledge here.  I did a two year postdoc in basal ganglia research before residency, and I spent a month at the PD iinstitute affiliated with the royal neurologic hospital - Queen's Square - in London, before getting board-certified in Neuropathology.