Tuesday, January 25, 2022

The Ever-Confusing Gapfill Season is Underway

Update: Novitas and First Coast published data templates and a due date of Feb 28 - here.


The Gapfill information season is Medicare at its most confusing.  

In Fall 2021, CMS priced about 65 of 100 new lab codes, and sent the other 35 into the "gapfill process."  In this process, all the MACs are supposed to gather information on the 35 gapfill tests, recommend prices, and submit the prices to CMS (ideally by March).  By about May, CMS publishes a list of all the MACs, all the codes, and all the proposed prices, for public comment.  In about September CMS publishes a list of "final gapfill prices" (the comments having been considered over the summer).

  • However, there's no central list of gapfill codes or central instructions on what to do, but you can hunt and peck and find the gapfill codes among the 100 codes priced on November 23.   
  • See my blog about the February 2021 process a year ago because eventually the 2022 process will probably lurch its way to the same configuration.

Although gapfill info is due in Jan/Feb, I couldn't find any MACs with information yet on how they wanted info submitted.   I tried search word "gapfill" at several different MACs and came up with nothing.   MolDx has a gapfill Excel spreadsheet to organize inbound information (you can find it at MolDx, and then hover over Forms, and then look for Gapfill.)   But they don't have any specific advice yet or a specific mailbox or portal to upload the info into.   I've been in calls where MolDx staff say verbally they'd also need a formal and more detailed cost breakdown than is requested on their form, but I've never found a place on the website that says they want that.  

In the past, Novitas and First Coast have set up a sort of "doodle poll" online where you can type in requested info into formatted web form pages.   I haven't seen any news about those for 2022, either.