Tuesday, June 9, 2026

CMMI ACCESS Program: Can Well-Intentioned Goals Conceal Adverse Incentives?

Header:  CMMI produces a JAMA Op Ed on its "ACCESS" technology and chronic care program.  I used an AI-generated essay to explain, then critique the program in some detail.

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This week, JAMA publishes an important paper from CMMI, which appeared online May 11.  See:

  • Outcome-Aligned Payments for Technology-Enabled Care—A New CMS Approach to Paying for Chronic Disease Care in Medicare.  
    • (2026)  Shiff J & Sutton A.  JAMA 335:1932-34.
    • Online here.
I've been experimenting with longer-form AI-mediated writing, and have created/supervised a ten-page, 5000-word essay in response:   


The ten-page essay is in the Google cloud as a PDF here.

The Essay Summary is here:

  • CMS’s ACCESS model is a serious attempt to modernize Medicare payment for technology-enabled chronic care. Rather than paying for visits, devices, app clicks, or care-management minutes, ACCESS pays organizations for measurable improvement in chronic disease outcomes — an elegant and potentially important idea. 
  • But it also exposes a deeper CMMI paradox: under-managed Medicare patients may need more care, not less. Better management can mean more drugs, physical therapy, behavioral health, monitoring, labs, and specialist follow-up. Judged too narrowly on savings, ACCESS may reward low-cost "metric improvement" while discouraging the costly care activation patients actually need. 

AI Attempts to Classify 100 New PLA Codes (Gets Migraine)

I asked Claude Opus and Chat GPT to make a classification system for the 102 PLA codes being considered for this summer's Annual Lab Meeting, which will price the 102 tests by the crosswalk or gapfill methods between now and November.

I noted that one approach is repeated binary decisions (human vs microbial; then microbial as pathogen panels vs other; and so on), but I emphasized that other classification schemes were possible.    

  • Here is a cloud zip file with (1) the original CMS excel, (2) the Claude excel, (3) the Chat GPT excel: 3 files 1 zip.
  • Note that both AI's produced complex Excels with many rows, columns, and tabs.  Chat GPT even included a bar chart.

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AI Attempts to Classify 100 New PLA Codes — Gets Migraine

The AMA CPT Editorial Panel creates special proprietary lab codes called PLA codes, or “Proprietary Laboratory Analyses.” In many cases, these describe tests unique to one laboratory, although some are FDA-approved, kit-distributed tests. There are now roughly 700 PLA codes, but no stable public classification system for them.

For the June 10, 2026 CMS Annual Laboratory Meeting, CMS posted a list of 102 new PLA codes to be priced by crosswalk or gapfill between now and November. The CMS spreadsheet includes a “Category” column, but it has not yet been populated. Public presentations proceed code by code, but by the July expert advisory meeting, CMS will impose some kind of category structure on the group.

So I asked two AI systems — Claude Opus and ChatGPT — to classify the 102 codes using the long descriptor column. As a starting point, I suggested one possible approach: repeated binary decisions, such as human versus microbial; then microbial as pathogen panel versus other; and so on. But I also emphasized that other classification patterns might work better. The challenge will be that PLA codes are not just “oncology” or “infectious disease.” They mix analyte, technology, clinical intent, specimen type, and algorithmic output in ways that do not fit neatly into one tree.

 

Monday, June 8, 2026

News Summary: WaPo: HHS Wants to Bring Physicians and AI Together

 


On June 4, 2026, Washington Post has a lead aritlce, "Push to bring AI doctors into American medicine," by Elizabeth Dwoskin.

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Chat GPT summarizes;

The Washington Post article is worth reading because it shows how quickly AI medicine is moving from speculative futurism into federal and state policy. The main story is not just that chatbots may help patients, but that some officials and entrepreneurs are now openly contemplating AI systems that diagnose, triage, refill prescriptions, and eventually practice medicine with limited human oversight.

The article centers on Amy Gleason, now advising HHS on AI, and describes a broader Trump administration push to integrate AI into health care through 

  • prescription-refill pilots, 
  • cardiovascular triage research, 
  • FDA digital-health fast tracks, 
  • Medicaid reimbursement for AI wellness tools, and 
  • possible future regulation of “independent AI doctors.” 
The article also gives WaPo readers the essential counterweight: physicians, researchers, and licensing boards warning that chatbots still make diagnostic errors, perform unevenly in real-world patient conversations, and may blur the line between advice and unauthorized medical practice.

For readers interested in FDA policy, digital health, medical liability, access to care, or reimbursement, this is an early map of a major coming policy battlefield.

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Chat GPT also researched Amy Gleason's background, as follows:

Amy Gleason began in nursing, including emergency-room nursing, then moved into health-care technology, especially electronic medical records, practice-management systems, interoperability, and patient access to data. An archived White House profile from the Obama-era Precision Medicine Initiative says she “began her career in nursing” and then spent years building and implementing EMR and practice-management technologies.

Her personal story is central to her public identity. Her daughter Morgan developed a rare autoimmune disease, often described as juvenile dermatomyositis / juvenile myositis, and Gleason became intensely focused on the failures of fragmented medical records and data access. The WaPo article says Morgan later uploaded years of medical records into ChatGPT, leading to a different diagnostic framing and trial eligibility.

Professionally, she co-founded or helped lead CareSync, a health-care coordination / records company, and later worked in digital-health roles including Russell Street Ventures, Main Street Health, and CareBridge.

In government, she worked with the U.S. Digital Service [bringing tech experts and government together, under Obama), including health-data modernization projects. She is now described as Acting Administrator of the U.S. DOGE Service, and Strategic Advisor to CMS, focused on modernization, interoperability, and AI/data systems in health care.

So, in one sentence: Amy Gleason is a former nurse turned health-tech executive and patient-data advocate whose personal experience with her daughter’s rare disease pushed her toward interoperability, federal digital services, and now AI-driven health-system modernization.

Sunday, June 7, 2026

AMA's New Digital Pathology Codes in "Category III": What If They're Not on the CLFS?

Key Lesson:

In 2026, AMA CPT began assigning whole-slide-imaging digital pathology codes to Category III, rather than the PLA pathway used for earlier WSI codes. That matters because PLA lab codes can move onto the Clinical Laboratory Fee Schedule and be priced by crosswalk or gapfill, while Category III codes are usually not nationally priced by CMS. 

If software-intensive WSI services instead fall into the Medicare RVU/practice-expense system, they face a known trap: CMS may count only technician time and tiny amortized equipment costs, while rejecting per-use software fees. CPT 92229, autonomous retinal imaging, is the warning case.  In the past, CMS has elected to leave such codes "carrier priced" rather than underprice them by 80% - but this does nothing to fix the underlying problems for software-intensive services.

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Saturday, June 6, 2026

How You Get CMS to Liberalize a Burdensome Rule (Case Study: Physical Therapy Orders)

Why You May Care...

 Many stakeholders approach CMS each year with a request to liberalize one or another rule - be it an administrative policy, an NCD, or some other problem.   While the example below is not related to molecular laboratories (my main readers), the example DOES show how multiple stakeholders coordinated - and over several years - to get  a meaningful policy change at CMS.

What's It About? Physical Therapy?

Here's the status quo before 2025.  A physician sees a patient who needs physical therapy.   The physician writes a REFERRAL or ORDER for a physical therapy evaluation.  The physical therapist spends 30 to 60 minues with the patient, doing careful tests and examples, and develops a plan of care.  The PT transmits the plan of care to the physician to countersign.   (This countersignature must be re-affirmed every 90 days).

Here's what people got.   Beginning in January 2025, the physician issues a ORDER or REFERRAL for physical therapy.  The physical therapist does the exam and prepared the report and plan of care.   It's transmitted back to the referring MD.  NEW RULE:  As long as the physician doesn't reach out and tell the P.T. there is a problem, the P.T. can ASSUME the plan of care is OK with the physician.

While that may sound like  a small change, I suspect PT stakeholders were very happy to get it.

Below I give a detailed Chat GPT summary of the rulemaking, requests, and the rationales discussed.  

Find the rulemaking at 89 Fed Reg 97710, 12/9/2024, specifically 97912ff (about eight pages).

 Take Home Lessons:  How It Worked [Chat GPT]

Wednesday, June 3, 2026

CMS Releases Data for "87798" Billing in 2024

On May 21, 2026, CMS released data by lab and by CPT code (also by physician and CPT code) for Part B payments in CY2024.

There's been a lot of discussion of changing payment policies for code 87798 in the past six months; 87798 can be use as a "probe" of the data set.

Find more about the data set here:

https://www.discoveriesinhealthpolicy.com/2026/06/cms-releases-rich-cloud-database-for.html

87798

First, we searched the dataset for all providers billing 87798.  There were about 1400 total providers of 87798 services.  Payments per provider ranged from $24M down to $109.  Total payments for 87798 in all 50 states were $436,743,071.  $436M.  Of that $436M, $139M or 32% went to TX and $36M to PA, $34M to FL, $23M to NJ.  This shows strong representation of Novitas and FCSO states for 87798 payments in CY2024.

Among all codes, 87798 was $436M, 81528 Exact Cologard was $306M, and 81479 was $572M (prior blog).

Services per bene - about 20 labs billed >30 services per year per bene, including 3 that billed >60 services per year per bene (87798).

The top providers of 87798 received $24M, $21M, $12M and $8M.  

Note that this is only about 16% of all 87798 payments.  Services per patient per year ran from 9 to 20.  The four labs were in TX (2 labs) and PA and FL.  


Top Four Labs Billing 87798: Their Overall Billings

We used these four labs to go back to the database and get all the CMS payments to these labs.  

The four labs are the "new universe" of claims.  The four labs were paid $131M in total, and got half of their Part B revenue from 87798 ($65M).

After getting 50% of revenue from 87798, they got 12% for candida amp probe (87481), 4% for 3-5 Resp Virus panel (87631), and about 4% each for Strep B Amp Probe (87653) and MultiOrg Amp Probe (87801).  These five tests brought in about 74% of all the annual revenue of the 4 labs.



Special Mention to Moldx Labs

Although it's not a big lab, I feel like honorable mention should go to MolDx Labs, in North Hollywood CA, which was paid $2.7M in 2024 by Noridian and MolDx, 58% for large panels of code 87798.   

Look up the NPI - from March 2024 - it's really "MolDx Labs." 




Tuesday, June 2, 2026

Predicting the Scientific Future: From UCSF's Robert Wachter

Robert Wachter of UCSF is both a medical leader and a futurist. In his newest book, A GIANT LEAP, he discusses AI in medical care.  From his early AI experiences in 2022, he extracted the following.

The story of whether AI would finally transform healthcare would mostly be about whether the healthcare system could implement these tools in ways that would produce better outcomes for patients, lower costs, and some relief for beleaguered doctors and nurses. 

And that, in turn, would be determined -- as much by history, politics, economics, pride, regulations, leadership, lawsuits, guilds, culture, workflows, inertia, greed, hubris, vibes, and zeitgeist as by graphics processing units, diffusion models, and neural networks.


Wachter, A Giant Leap, 2/2026, Preface.



CMS Releases Rich Cloud Database for CY2024 Claims, Medicare Part B

 If you love CMS Part B data, Christmas comes every May or June, when CMS releases extensive cloud data for all labs and all  physician providers of every CPT code.   

CMS classes this as;

Data.cms.gov

>> Provider Summary by Type of Service

>> Medicare Physician and Other Practitioners [incl labs]

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

The 2024 data set was released on May 21, 2026.  The same source has year-by-year back files to 2013.  the 2024 data has 9,781,673 rows.   You use it by filtering - for example, every lab that got paid $1 or more for code 81479 (filter on HCPCS = 81479).

For my blog on microbiology, 87798, here.

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I filtered for codes ending in M or U, plus 811, 812, 813, 814, 815.   This misses the molecular microbiology codes, which are in different ranges up in the 87000-87999 range.  

The codes I did filter - without 877 microbiology - were paid $2,813,342,286, meaning, amost 3 billion dollars.

This produces lines as "lab x code" so, for example, 81479 is split over many lines, many labs.

The top code was 81528, Exact Sciences, $306M, or 11% of all molecular payments.  Next ccame Natera, CareDx, and Caris, all for code 81479, respectively for $104M, $102M, $100M.

The top 10 codes were paid $1.2B or 41% of all molecular payments. About 30% of the top 20 lines were 81479 payments. 81479 providers were paid $572M, 95% to the top 12 billers of 81479. 81479 used only in MolDx states. Below: Click to enlarge.

click to enlarge


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I've heard there was a recent boom in uncontrolled (no LCD) payments for 81419, epilepsy panel.  I used Ctl-Alt-L to turn the highlighted "CODES" column into a drop-down-box selection column and checked only 81419.   Let's remember, just because codes like 81419 epilepsy, 81443 expanded carrier panel (e.g. cystic fibrosis), or 81440 mitochondrial genes, rapidly rose greatly in utilization and primarily in TX and FL, where Novitas did not have controlling edits, does NOT mean that anything inappropriate was occurring.   

Top payments for 81419 epilepsy panel were $73M with with half of national payments going to the top 6 epilepsy panel labs.

Note the states; TX, FL, NJ, PA, TX, FL, FX, FL.  

Nearly all labs getting paid for Epilepsy Gene Panel 81419 in Medicare, were under the Novitas and FCSO MACs, which had in recent years paid around a billion dollars for 81408 (Tier 2 code) and adjacent codes.  That's a code not covered by any other MACs, and one whose payments were apparently finally stopped by OIG.

While payments stopped for 81408 around 2023, by 2024 labs provided market access for genetics to patients under a different uncontrolled code [no LCD], 81419, literally just ten digits away in the code book.   

click to enlarge

I took the top 4 labs for 81419 (as above - FL, FL, PA, TX) and pulled all of the billing for these four NPI's for 2024.   The four labs were paid $27M for 81419 and $118M for all genetic codes.  Other leading codes from these four labs were 81440 (mitochondrial genes), 81443 (inherited conditions aka expanded carrier panel, CF etc), 81162 (BRCA).


At a glance, these genes seem medically unrelated.  One lab billed the same number of patients for 81443 and 81448, and the same number for 81181, 81183, 81343.  

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AI CORNER
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I gave the data to both Claude Opus and Chat GPTClaude noted that many of the labs - about a dozen out of 48 nominally independent labs  - billed the exact same charge, to the penny for 81419.   That's a clever observation and one I never have looked for.   Of course, that could happen for many reasons and I do not view it as suspicious.  Claude also wrote, "A single elderly Medicare beneficiary rwho medically requires an epilepsy panel + a 100-gene mitochondrial-disease panel + a prenatal-style carrier screen is not a workup that exists in nature."   Claude also asserted that many of the single-gene codes were already inside 81443, something that CMS edits should have known.   (I have not manually checked that.)

Of the four labs we checked based on high 81419 billing, one billed only 3 CPT codes, one billed 18, and the other two (both in the same city) billed about 65 codes each.  

Chat GPT studied the Excel's and opined, "The data do not look like an organic epilepsy-testing market. They look like a rapid, concentrated exploitation pattern around a high-paying, apparently weakly edited genetic CPT code, with the strongest signals in Florida/Texas, and especially around a small number of labs whose broader code portfolios show high-volume use of many unrelated genetic codes, not a coherent epilepsy-testing service line."  It tallied 7 of 48 labs billing 81419, as all being in Deerfield Beach FL.  Labs billing the same charge were as little as 1000 feet apart.

A New Commercial Source for Rapid Complete Medicare Claims Research LUMA CLAIMS

CMS has some free databases for Part B claims - like this one for annual Excel spreadsheets and this one for a cloud database x CPT code x Provider Name.  And CMS sells anonymous data files of claims data, too.

Now there's a new vender in town.  

I'll copy below an email I got today about LUMA CLAIMS dot COM.   It includes nearly real-time CMS claims processing data (through February 28, about four months ago).  Wow.    Pricing info was not readily available.

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Continuing our partnership with medicareclaimreports.com (now https://lumaclaims.com/), Parrish Law Office is pleased to announce that initial claim approval/denial information for ALL Medicare Part B CPT codes is now available from January 2020 through February 28, 2026. Using a new interactive interface, custom reports examining approval differences by Medicare Administrative Contractor, provider, and State, and time based analyses can be created. Charts, graphs, and raw data of the reports can be downloaded. The data is particularly useful in identifying approval/denial trends and issues, and where Medicare has not issued a local or national coverage determination. 


We use these reports to show that Original Medicare has been covering something when a denial asserts that the item is experimental/investigational.


If this information would be useful in your business, please contact Parrish Law Office for more information or click on this link: www.lumaclaims.com


Debra M. Parrish, Bridget Noonan

Parrish Law Offices     www.dparrishlaw.com


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https://lumaclaims.com/









Sunday, May 31, 2026

Using AI: (1) Finding Half-Remembered Papers; (2) Finding Papers of Major Importance. For: Computational Pathology.

Summary of This Long Post :Creatively Using AI at Work
Case Study: Digital Pathology

This blog begins with an unexpectedly mundane task: finding two important digital pathology papers that I could only half remember. 

You know the feeling: I recalled the ideas, but not the authors or titles. Using ChatGPT as a research assistant, I tracked down the Dawood paper on confounding and shortcut learning in H&E-to-genomics prediction and the Trost/SPARK paper on interpretable, multi-layer computational pathology. 

The conversation with AI then expanded into something more interesting: How do we identify papers that genuinely reshape a field? Along the way, ChatGPT located related author networks, suggested additional field-defining papers, and helped formulate an operational definition of a high-impact publication: a paper that future authors must cite, answer, distinguish, or defend themselves against. 

The result is both a practical demonstration of AI-assisted literature retrieval and a discussion of how scientific fields change.


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This weekend, I used Chat GPT to look up two papers from the last six months that I half-remembered, and not the first author.   (Spoiler alert: "Dawood" and "Trost.")

Then, I asked Chat GPT to find recent papers that share several authors from the Trost author list.

Then, I asked Chat GPT to find five-or-so digital pathology papers Z1, Z2, etc, from the past year, of equally high originality and potential impact.   (Impact:  Operationally: If you write a paper on on topic X in the next 12 months, it's guaranteed the editor or reviewers will require you to address [high impact paper Z.])

I'm reproducing my dialog with Chat GPT more or less as it occured.

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Saturday, May 30, 2026

A Must-Read Article: Use of Comprehensive Genomic Profiling in Metastatic Cancer of Medicare Beneficiaries

JAMA Network Open publishes a must-read paper on comprehensive genomic profiling (CGP) by Chow et al.   The paper headlines "a difference in Medicare Advantage patients" - less profiling - but the difference is tiny (25% vs 26%!).   But there are LARGE differences by geography, and LARGE differences by cancer type.

Find it here: https://jamanetwork.com/journals/jamanetworkopen/fullarticle/2849451



How was CGP defined?

First, they use the term "BGP" - broad genomic profiling - to mean 10 genes or more (including by old-school stack coding of individual oncogenes, think EGFR+KRAS+etc.)   

They count codes like 81445, 81455, PLA codes for CGP, and also count 81479, especially critical in MolDx states.  See Supplement, Table 2.  TAT wasn't an issue.  The time span was 2 months before surgery and 6 months after.  

The method picks up CGP as 81479 under Moldx; but (I believe) misses CGP performed as part of an inpatient DRG payment and not coded separately.

How was metastatic defined?

I'm not sure.  They write, "We restricted the sample to patients with metastatic cancer based on the presence of a secondary malignant neoplasm ICD-10 code (C77, C78, or C79) in the 2 months before through 6 months after their initial cancer diagnosis. Patients with a solid tumor cancer diagnosis code in the year prior to their index date were excluded, as we aimed to focus on patients with incident disease."

It's ridiculous we have a zillion ICD-10 codes and codes for "bitten by a duck on the left hand" but not clear coding for "metastatic cancer.  Insane.

What was the Medicare Advantage difference?

Statistically valid, but very tiny.   254,720 patients.  About half Medicare Advantage, median age 74, "metastatic cancer."  25.3% had CGP/BGP, of which 25.8% FFS, 24.6% MA insurance.

What was the impact of geography?

Big, but very patchy.   Here is a heat map. Range of CGP/BGP about 15%-35%.

What was the impact of cancer type?

Large; about 40% in metastatic lung cancer, about 10% in prostate and kidney cancer, and in between those find 15% in breast cancer, 25-30% in colon cancer.


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AI Corner
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Here's a summary by Chat GPT:

 

A Must-Read Article on CGP in Medicare Metastatic Cancer

JAMA Network Open has published a must-read paper by Chow et al. on the use of broad genomic profiling — what many of us would call comprehensive genomic profiling, or CGP — in Medicare beneficiaries with metastatic cancer.

The article headline, in effect, is about Medicare Advantage versus traditional fee-for-service Medicare. That is a real finding. It is statistically significant. But it is also worth saying plainly: the absolute difference is tiny. In this cohort, 25.8% of fee-for-service beneficiaries received broad genomic profiling, compared with 24.6% of Medicare Advantage beneficiaries. That is a 1.2 percentage point difference. With more than 250,000 patients, even tiny differences become statistically real. But in policy terms, the much larger story is elsewhere.

The Biggest Finding: CGP Remains Underused

The big story is that most Medicare beneficiaries with metastatic cancer did not receive broad genomic profiling at all. Overall, only about one-quarter of patients received BGP during the study window. Even among cancer types where broad genomic profiling was explicitly recommended, fewer than half of patients received it. For the precision oncology field, that should be the flashing red light.

After years of guideline development, FDA approvals, NCD 90.2, MolDx policies, commercial test growth, and endless conference panels on precision oncology, only about one in four older Medicare patients with newly diagnosed metastatic cancer received broad genomic profiling in this study.

The Medicare Advantage Difference: Real, But Small

The Medicare Advantage finding should not be dismissed, but it should be kept in proportion. The authors found FFS patients were more likely to receive BGP, with an adjusted odds ratio of 1.08 overall. The gap widened over time, and it was larger in cancers with equivocal guideline recommendations than in cancers with explicit recommendations.

That pattern is interesting. It may suggest that Medicare Advantage plans are more restrictive at the margins, especially where clinical consensus is less forceful. But the MA-versus-FFS contrast is not the dominant effect in the paper. It is a modest signal sitting inside a much larger national underuse problem.

For policy readers, the take-home message is not “Medicare Advantage blocks CGP.” The better summary is: CGP remains underused in metastatic cancer; use varies enormously by geography and tumor type; and Medicare Advantage may add a small additional access headwind, especially in less clearly guideline-mandated settings.

Geography: The Much Larger Variation

The second big story is geography. Chow et al. found striking variation across hospital referral regions, with adjusted BGP use ranging from about 14% to 36%. That is not a subtle payer effect. That is a map of uneven adoption.

In one region, a patient with metastatic cancer may have roughly a one-in-seven chance of receiving broad profiling; in another, more than one-in-three. The authors even note striking differences between nearby regions, such as San Angelo and Odessa, Texas. That kind of variation suggests local practice culture, access to oncology networks, molecular tumor boards, ordering workflows, lab relationships, and regional reimbursement habits may matter as much as — or more than — the broad category of MA versus FFS.

Cancer Type: Lung Leads, Others Lag

The third major story is cancer type. Broad genomic profiling was used far more often in lung cancer than in some other metastatic cancers. Lung cancer was around the 40% range, while prostate and kidney cancers were much lower, roughly around 10%. Breast cancer was also surprisingly low, around the mid-teens, while colorectal cancer was closer to the 25% to 30% range.

These differences are not random. They reflect the historical depth of biomarker-driven therapy in lung cancer, varying guideline strength, oncologist expectations, and perhaps the availability of obvious targeted-treatment pathways.

How Chow et al. Defined Broad Genomic Profiling

The paper uses the term BGP, for broad genomic profiling, rather than CGP. Their working definition is sequencing of 10 or more genes on a single day. That is an important operational definition. It means the authors are not just counting 500-gene panels. They are also trying to capture broader molecular testing through older billing patterns, including “stacked” individual gene codes.

The supplement is especially useful here. The authors count familiar genomic sequencing codes such as 81455 and 81456, intermediate panel code 81445, many PLA codes for named commercial tests, and unlisted molecular pathology code 81479. The inclusion of 81479 is especially important in MolDx states, where major CGP tests may appear under an unlisted code rather than a neat, named, national CPT code.

Claims Data: Powerful, But Imperfect

Claims-based CGP studies always have blind spots. If a genomic test is performed during an inpatient stay and absorbed into the DRG rather than separately billed, it may not be visible in the same way. Conversely, an algorithm that counts 81479 or stacked codes has to make assumptions about what the code represented.

Chow et al. address this thoughtfully, but the limitation is inherent in claims research. Claims are not laboratory information systems. They are billing exhaust.

How “Metastatic Cancer” Was Defined

The metastatic cancer definition is also worth pausing over. The authors define metastatic disease using secondary malignant neoplasm ICD-10 codes — C77, C78, or C79 — during the period from 2 months before through 6 months after the initial cancer diagnosis. That is a reasonable claims-based approach, but it also highlights an absurdity of our coding system.

We have ICD-10 codes for astonishingly granular events, including famously silly external-cause examples, but in real-world oncology data, “metastatic cancer” still has to be reconstructed clumsily and indirectly. 

For a health system that wants to measure quality in precision oncology, that is a serious infrastructure problem.

Policy Takeaway: This Is an Implementation Gap

This article is valuable because it gives precision oncology stakeholders a national claims-based picture of where we are. The picture is not reassuring.

Better coverage policy is part of the answer, but probably not the whole answer. The geographic findings point to implementation gaps: ordering systems, oncologist awareness, tissue pathways, reflex testing, payer prior authorization, lab contracting, and institutional habits. The cancer-type differences point to guideline clarity and therapeutic actionability. 

The claims-code issues point to the continuing difficulty of measuring modern molecular diagnostics in a payment system still built around older coding concepts.

Bottom Line

Chow et al. provide much more than a Medicare Advantage paper. They provide a snapshot of precision oncology’s incomplete diffusion into real-world Medicare cancer care. The headline may be MA versus FFS. The real story is that access to broad genomic profiling remains inconsistent, underdeveloped, and highly dependent on where the patient lives and what cancer label appears on the claim.

 



Thursday, May 28, 2026

NGS MAC Updates LCD in a Few Weeks

 I hear many people complain that it takes years - literally, years - to get updates to LCDs, let alone, consider opening a NEW LCD on some topic.

As shown below, the NGS MAC proposed some edits to its molecular LCD in April, the comment period closed on May 16, and the revised LCD was posted on May 28.  Including responses to 2 submitted comments.

Yay team.

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While the CMS name on the document is "National Government Services MAC" the organization refers to itself as "Wellpoint Federal" and the CMD emails are the domain Elevance, which has some relationship to the historic Anthem BCBS.  (See my blog on the MAC and MAC Parent name merry-go-round.)



Wednesday, May 27, 2026

Can AI Write Deep Strategic Business Reports? We Compare Claude and ChatGPT on "Digital Pathology"

 Can AI Write Deep Strategic Business Reports?

More and more, I am seeing complex reports automatically generated by Claude Opus 4.7 and by Chat GPT, especially in its "deep research" mode.  (I have the $20 subscriptions to each).

I gave both AI's a prompt to do a business analysis of two competitors in the digital pathology space (I chose Philips and Roche).  Claude Opus took about 15 minutes to generate a 13-page report.   Chat GPT in "deep research" mode took about a half hour for a ten-page report.

Here's the take-home lesson, per Chat GPT:

  • Two LLMs were given the same business-research prompt: compare Philips and Roche/Ventana in the U.S. digital pathology market. 
  • The results were both useful, but revealingly different. 
    • Claude Opus produced the more vivid strategy memo, framing Philips as a “platform-of-platforms” and Roche as an integrated diagnostic “system of record.” 
    • ChatGPT Deep Research produced the more cautious diligence brief, emphasizing FDA status, RUO caveats, U.S. commercialization limits, and reimbursement realities. 
  • In short: Claude gave the sharper narrative; ChatGPT gave the safer client memo.
Find the full 27-page PDF, which opens with a two-page comparison, and then reproduces each report in full.







Tuesday, May 26, 2026

How MACs Price Major Services That Lack Fixed RVU's (Case Study: PET CT)

Header: AMA CPT has created some new Category III codes for whole-slide imaging proprietary tests.  However, as of May 26, CMS has NOT added these clinical laboratory codes to the summer CLFS pricing process.   What happens to Category III codes in terms of MAC pricing?

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CMS assigns RVU-based national prices to nearly all AMA CPT codes in Category I (aside from clinical laboratory tests).   However, one counter-example is PET-CT, which does have fixed, national prices for physician interpretation (around $100) but there is no national Part B price for the technical component, or for the global service (meaing, scan + interpretation) in the non facility setting.

In the facility setting, Medicare sets a hospital outpatient rate (about $1400 for 78815, varies with geography).  This is via the ambulatory payment classification (APC) of code 78815 under OPPS policy.

In the non-facility setting, where >800,000 PET CT scans are performed, MACs set prices for 78815 for the technical component (or the global claim).   

In a nutshell, high-end prices, probably for global claims, ran to the $2300 range in California.  There was a plateau of pricing from about $1300 to $1700.   There was a sharp drop-off with claims paid in the  $200-$900 range, and then many claims in the $120 range (interpretation only on the RVU fee schedule).

For comparison, CMS pays about $1400 for the technical component of 78815 PET CT in the hospital outpatient setting (with regional adjustments.)

What's it mean?

First, it's tricky, since the Part B database I'm pulling from lumps together all forms of Part B 78815 payment (whether PC only, TC only, or global).

California TC Can Be Rationalized. MAC behavior when freed from RVU pricing is confusing.   Generally, the maximum Part B RVU delta in low to high priced areas is +50% of the base RVU rate (e.g. for 88361, computer assisted IHC, TC or global). 

This +50% geographic hike for priced RVUs across geographies would lift the $1400 hospital outpatient APC to the $2000 range, exactly what we see in California.   So it's reasonable to guess that Noridian used the APC price of $1400 and the regional multiplier (in SF, LA, etc) of +50% to get around $2000.

Payments $200-900 Seem Damn Odd.  It's unclear how you get the prices between $200 and $1000.   

  • If these are TC alone, the prices seem "too low," at least, compared to the  APC benchmark of $1400.   
  • On the other hand, if these are professional component alone, it should be impossible to pay over the $100-150 range due to fee schedules for 78815-26.   

Take-Home Lesson for WSI Codes

Based on AMA CPT Summary of Panel Actions documents, at the February Palm Springs meeting they created two WSI codes (X568T, X569T), final code text to be released 7/1/2026.   At the May Boston meeting, they created additional WSI codes for breast and prostate cancer respectively (X623T, X624T), I believe also to be released 7/1/2026.   

If CMS continues to leave these "off" the summer lab meeting schedule, then they will be included in summer policymaking for the Hospital Outpatient (OPPS) environment, and assigned to pathology category prices or new tech category prices for OPPS.   

MACs may use these Category III OPPS prices as reference prices for Category III codes in Part B, just like MACs used the APC price $1400 for 78815 as a reference price for Part B.


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Sidebar:
Using Chat GPT for Data Analysis

I downloaded all Part B payments for 78815, PET CT, for CY2024.  

I asked Chat GPT to compare pricing >$1978 with pricing in the band $909-1197 (low, but believable for TC).

Over $1978

Click to enlarge

$909-1197
Click to enlarge

Chat GPT adds this text:

The contrast is striking. The high-payment band is not a general national distribution; it is dominated by California, with a bit of New York. The low-payment band is much more of a multi-state pattern, led by SC, OH, FL, MN, TN, and scattered others.

Both bands in the spreadsheet are Place of Service “O” lines, so this comparison appears to be within the office/nonfacility physician-supplier world, not hospital outpatient OPPS. That makes the spread more interesting: for 78815 technical/global office PET/CT, allowed amounts are not converging around a single national TC price. Instead, the data look like a patchwork of MAC/locality/carrier-priced technical-component behavior, with California standing out at the high end.

The policy takeaway is that although the physician interpretation of 78815-26 is nationally PFS-priced, the nonfacility technical economics of PET/CT remain quite variable. In this slice, the high band is roughly double the lower band: about $2,183 weighted average versus $1,073 weighted average. That is a large swing for what is nominally the same PET/CT skull-base-to-mid-thigh service.


United Healthcare Publishes Variations from "Date of Service" Rule

Medicare's date of service (DOS) rule for laboratory tests - often given the name, "14 day rule" - gets a new spin in a publication from United Healthcare affecting millions of beneficiaries.

Thanks to Ashley Zarling for highlighting the event at LinkedIn.

CMS Date of Service.  Since about 2001, CMS has set the "date of service" rule for lab tests - both clin lab & pathology - as teh date of specimen collection, and separate rules (not the DOS regulation itself) often lead to hospital inpatient and outpatient lab tests being bundled and not separately payable.  CMS bundles all inpatient lab tests, even those ordered 13 days after hospital discharge, to the hospital inpatient DRG, and CMs bundles most lab tests for outpatients to hospital outpatient events like office or ER visits, tagging them with a "status indicator" for bundling or, rarely, separate payment.  42 CFR 414.510   See also an explanatory webpage at CMS.

Medicare Advantage plans don't have to follow this rule, although I suspect they usually do, and other commercial insurance plans definitely don't have to follow this rule - but they may often elect to, by stating that as a first principle, Medicare billing rules will be followed.

New Rule at United Healthcare

The new rule at United Healthcare was published May 1, 2026, as new "Question 9" of document  2026R0111B, rules for submitting a 1500 claim form.  United states that, "This reimbursement policy applies to all health care services billed on CMS 1500 forms and, when specified, to those billed on UB04 forms."

The rules have a number of entries about United's use of MolDx and Z-codes.

Q: Which date should be submitted on the claim for reflex testing?

A: According to CMS, when reflex testing is performed, the date of service (DOS) submitted for each test must be the date the reflex test itself is performed, not the date the original specimen was collected.

I'm not sure exactly where United gets this rule from ("Accoding to CMS...").   United has a blanket reference for all its rule, referring to CMS, CMS Manuals, or Other CMS Publications.

Without knowing a written exception, I would have said the date of reflex testing would generally be the date of specimen collection - the master CMS rule for DOS, unless the test was ordered > 14 days after inpatient or outpatient discharge.   

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https://www.uhcprovider.com/content/dam/provider/docs/public/policies/comm-reimbursement/COMM-Molecular-Pathology-Policy-Professional-Facility.pdf

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See a "deep dive" AI written research article on DOS back to the 1990s, here.