Friday, March 29, 2019

CMS Lab Pricing Public Meetings: June 24, 2019 (Public), July 22-23 (Advisory Panel)

CMS has published, in the Federal Register, advance notice of its annual summer meeting for the pricing of new laboratory CPT codes.   The public meetings will be Monday, June 24, 2019.  The Advisory Panel will be Monday-Tuesday, July 22-23.

Here are the key dates in full:
  • Circa May 20, 2019, CMS releases agenda 30 days in advance of meeting (list of all codes)
  • June 10, 2019, Presentations due
    • Same date for public registration for non-presenters
  • June 24, 2019 (Monday), Public Meeting at CMS, Baltimore
    • Location: CMS Main Auditorium
  • July 8, 2019, Comments within 2 weeks of public meeting
  • July 22, 23, 2019, Advisory Panel on Clinical Lab Tests
    • July 1, 2019, deadline to register to attend Advisory Panel
  • Early September - Proposed Prices
  • Early October - Deadline for comment on proposed prices
  • November - Final Fee Schedule for CY2020
    • 60 Days after Final Fee Schedule, deadline to submit "reconsideration"
    • Reconsideration simply brings the code back for the July 2020 meeting
See the CLFS Public meeting announcement > here.  See the July Advisory Panel announcement > here.

Track further announcements at the CLFS public meeting webpage here, and the Advisory Panel homepage here.

Foreign Nationals

Not always clear in these announcements, if you are a foreign national, you must reach out to CMS much farther in advance and provide additional materials.  Otherwise, you'll be stopped at the front gate ... even though CMS has otherwise accepted your online registration.  I've seen it happen.

CMS Preferences (Stated August 2018)

Last year, in program materials released in August, CMS announced that in general, it preferred single crosswalks and not stacked crosswalks, and crosswalks x1 in preference to fractional crosswalks (e.g. x1.5 or x2.5).   These are not absolute rules, but now they are stated CMS preferences.  Codes that can't be easily crosswalked under these preferences are more likely to be turfed to the MAC gapfill process which spans the following calendar year.

PLA Codes

On March 21, 2019, AMA updated its PLA code list (here).  I believe last year's meetings included all PLA codes released to AMA's website up to June 1, and this new meeting will cover all PLA codes released between August 31, 2018 and June 1, 2019.   (For the latter codes, the submission deadline is April 3, and the finalization will be at the May 8-9 CPT meeting).  Roughly, this is PLA codes 0062U to 0104U (42 codes), plus let's guess another 20-30 codes for May 2019.  That means there will be 60, 70, or more PLA codes in the June 2019 summer meeting, plus the dozen or more "regular" CPT lab codes generated this year.   

PLA codes become active for use up to several quarters before their CMS pricing cycle.  In contrast, regular lab and other CPT codes generally aren't active for use at all, until after the CMS pricing cycle completes.  

An Additional Date to Watch!

Since pricing arguments and powerpoints are due by June 10, applicants should get started on that process by early May, understanding the rules, picking crosswalks or arguments, considering alternatives.  If you want to consult with stakeholder groups (like lab associations) for advice, you should have draft materials written by the beginning of May.