Friday, May 4, 2018

CMS Publishes Full Code List For New Lab Codes; Big Revisions to BRCA

CMS holds an annual public meeting to allow public comment on its pricing options for new, and revised, AMA CPT laboratory codes.   CMS publishes an initial list (mostly PLA) codes in early April; CMS has now published a full list of 81 codes.   BRCA codes are scheduled for extensive revision and CMS repricing.


  • See the CMS lab meeting webpage here.
  • See the full Excel spreadsheet (as a zip file) titled "as of April 30 2018," here.
    • The full Excel spreadsheet should have 81 agenda items.
    • (Note they've left up, for now, a partial spreadsheet posted a few weeks ago.)
Registration for the public meeting is open until June 11 (click the "register" link).   Note there are also explicit instructions for your one slide Powerpoint presentation format, click on Power Point Presentation Template.  

Both registration and slides are due June 11; note that the meet could fill up prior to that date due to limited audience space (for people) and limited agenda time (for slides).

What's On Deck?

The agenda lists 2 tests for pricing reconsideration, 81334 (RUNX1, in AML) and 81326 (PMP22, in Charcot-Marie-Tooth neuropathy).

Items 3-29 (26 items) are PLA codes, the new quarterly "proprietary lab analysis" category of code.  These are diverse codes; some human genetic, some microbial, some MAAA and some FDA approved tests.

Items 30, 31, 23 are "administrative MAAA" codes (such as 0011M).

Items 33-81 are Category I genomic CPT codes for the most part and mostly single genes (80X01 is a dihydrotestosterone chemistry code).  

Agenda items 45-49 are revised BRCA codes.
  • 81X78 will be BRCA1, BRCA2, full sequencing.
    • 81X79 will be BRCA1, BRCA2, full dup del analysis (e.g. large rearrangements)
  • 81X81 will be BRCA 1, full sequencing and 81X82 will be BRCA 1, full dup del analysis.
  • 81X83 will be BRCA 2, full dup del analysis
The "new codes" agenda doesn't list deleted codes, since a deleted code does not require pricing, so the status of some existing BRCA codes like 81211 isn't explicit from the CMS CPT listing.   In its public report on the February 2018 AMA meeting, the AMA summarized as follows:
"Accepted addition of five new codes to report full sequence analysis, full duplication/deletion analysis [for] BRCA1 and BRCA2; revision of code 81162 to include full duplication deletion analysis; revision of 81216 to include HUGO gene name; deletion of 81211, 812131, 81214."  The codes-affected list was 81162, 81211, 81212, 81213, 81X78, X79, X81, X82, X83.
AMA could, possibly, make alternations between the February meeting public report and the code book going to press in summer.  Basically, from the above information, it looks like they've left in place 81162 (BRCA1, BRCA2, full seq + full dup del) but if a lab is going to report only sequencing or only dup del, it could use 81X81 alone or 81X82 alone instead of 81162.   (I would strongly predict a CMS edit not to use 81X81+81X82 together as stack codes.)   PAMA has impacts in all this, because 81162 drops in price under PAMA while 81211 rose in price under PAMA, at least, until it's deleted.