Monday, June 1, 2020

CMS Adds 32 Last Minute CPT Codes to Summer Lab Pricing Meeting; U0004 Surprise

Within the past couple days, CMS updated the file of new 2021 lab codes that will comprise the agenda of the June 22, 2020 clinical laboratory fee schedule public meeting.

As it has done in several past years, CMS updated the code list (previously about 98 codes long) to accommodate both PLA codes and 80,000-series CPT codes released by AMA in May 2020.   Right now, the CMS spreadsheet is the only place these codes are publicly visible.

One twist - this year, public comments on the codes are due June 4, per the Federal Register meeting announcement.  That's this Thursday and thus only a few business days after the CMS agenda update!  (Nominally, CMS is supposed to put out the meeting agenda 30 days in advance to allow the public to view it and develop comments).  

  • Here's the CMS home page for the public meeting (which will be "virtual" this year): here.
  • Here's the link to the Federal Register meeting announcement and registration instructions: here.
  • Here's the updated cloud zip file for codes under review: here.
    • It's called CY 2021 Clinical Laboratory Fee Schedule Test Codes ZIP on the CMS page.
    • It's way at the bottom of the web page.
  • I've put a cloud copy of the Excel in the cloud here.
    • In which version, I created a second tab with the newest codes.
Code 0202U is for a special BIOFIRE respiratory panel that includes COVID.  That's fast action: the test was FDA EUA approved May 1, code released and effective by AMA, off-cycle, on May 20, and by June 1, it's on the agenda for June 22 pricing by CMS.   

In total, there are 21 new PLA codes.  There are 7 new CPT (80,000 series) drug codes, and one MAAA microbiology code (still a pretty rare occurrence; and a Category I code to boot).  In total, not counting U0003/U0004, there are 21+11 or 32 new codes for the public to scramble to comment on by June 4.

Big Surprise: U0003 U0004 On the List - Typo?

CMS has created four codes for COVID detection - U0001, U0002, U0003, U0004.

U0003-U0004 were created by CMS in mid-April by an Administrator's Ruling, which stated the pricing would be $100 for each.  I'm puzzled that these codes are out for public comment on the pricing already set by CMS in a major regulatory ruling.   Possibly, CMS views the Ruling as adequate to set a price for use, but not enough to put it on the fee schedule without public comment.  Alternatively, the inclusion of U0003/U0004 might be a typo.  (It's at a minimum a change of heart, since these codes were created in mid April and were not on the May 8 code list agenda.)