Wednesday, June 24, 2020

CMS CLFS Annual Public Comment Mtg: Full Unofficial Transcript Here!

On Monday, June 22, 2020, CMS held its annual public comment meeting on some 130 new CPT codes for the CY2021 fee schedule.   The meeting was webcast, but CMS has not yet posted archival video on its YouTube channel (if it will).

CMS did an excellent job of pulling off this complex meeting as a webcast.  CMS also introduced some innovations, such as posting public presentations in advance of the meeting.

I've had an unofficial full transcript prepared, and provide a link to the cloud file, below.

PPT Files
A few days before the meeting, CMS posted nearly all the PPT presentations on the CMS website.  I've put a single ZIP file with all the presentations in a cloud file, also.  (This 8 Mb ZIP file includes copies of the meeting agenda and an Excel file of all 130 new code names, both of which are provided as separate links on the CMS website).

Next steps:  
CMS will hold a public advisory board meeting which will vote on pricing options for each code - July 29/30.   CMS will announce its proposed new test prices in September, triggering a final additional public comment period before CMS posts final prices in November.

  • Unofficial June 22 Transcript here. (95pp)
  • Zip file of all presentations here. (8 mb, 30 files)

The CMS home page for the CLFS public meeting is here.
The separate CMS home page for the advisory panel and its July 29/30 meeting is here.


Some notes on the day's work.

  1. A lot of interest in how CMS would price COVID codes U0001-U0004, provisionally priced by CMS at $50 and $100.
  2. Request to get a higher price for FDA validated test PIK3CA (0154U, Qiagen, Item 03).
    1. Lab PMMM has a proprietary minimal residual disease code, 23 genes, and would like gapfill for 0171U rather than crosswalk to heme oncogene panel 81450.  MRD threshold testing stated to be more complex than typical leukemia gene testing.
  3. Genomind requested a crosswalk to unlisted code 81479 (under which Myriad Genesight is paid circa $2000).  Generally, CMS determines it can't crosswalk to an unlisted (nonspecific) code since there is no fee schedule legal price for an unlisted code. (Item 11.)
  4. Neurodiagnostics brought a fibroblast-based Alzheimer diagnostic test to the panel (Item 05).
  5. Biofire was back.  Last year, they requested codes for their test panels that would be priced lower than the corresponding general CPT code for viral panels.   This year, they have their very new code for a respiratory panel including COVID.  PLA code 0202U, Item 27.
  6. In the past several years, there have been a lot of proprietary urine tox panels - not this year.