Every fall, CMS releases new edits called "P2P" Procedure to Procedure Edits, which are pairs of codes are unpayable on the same claim. (These are released as gigantic Excel spreadsheets). And every fall CMS also releases its manual for correct coding in each area of AMA CPT.
These documents have been released for 2023. There are only tiny changes in the lab section of the manual, and regarding the new genomic sequencing tumor codes for RNA, CMS only quotes a phrase already in the code descriptor itself.
Of more interest, I think they allow both a DNA code and an RNA code for solid tumors and for hematologic cancers (both, 5-50 gene range), but CMS pivots and doesn't plan to allow the 50+ tumor gene code to be used with its new RNA-only sibling codes.
The New CMS Resources
NCCI home page here.
Find the new P2P edits in Excel here.
Find the new coding manual for 2023 here.
The AMA GSP CGP Changes
Basically, AMA has three familiar codes for cancer genomics, 81445 (solid cancer, 5-50 genes), 81450 (hematolymphoid cancer, 5-50 genes), and 81455 (any cancer, 51+ genes).
These 3 codes are defined as representing either DNA only reports, or DNA/RNA reports when the DNA and RNA is done in an integrated procedure.
New. When RNA is done as a separate procedure, or later, AMA has new codes.
These are 81449 (RNA analysis, 5-50 genes, solid cancer), 81451 (RNA analysis, 5-50 genes, hematolymphoid cancer), and 81456 (RNA analysis, 51+ genes, any cancer.
Let's list them as AMA does:
- 81445 (5-50 genes, solid cancer, DNA or DNA/RNA analysis)
- 81449, same but RNA only
- 81450 (5-50 genes, hematolymphoid cancer, DNA or DNA/RNA analysis)
- 81451, same but RNA only
- 81455 (51+ genes, any cancer, DNA or DNA/RNA analysis)
- 81456, same but RNA only
- Testing for somatic alternations in neoplasms may be reported differently based on whether combined methods and analyses are used for both DNA and RNA analytes, or if separate methods and analyses are used for each analyte (DNA only, RNA only).
- For...a single combined method, use 81445, 81450, 81455.
- For targeted genomic sequence analysis of RNA when performed using a separate method, report 81449, 81451, 81456.
- For...DNA analysis AND RNA analysis performed SEPARATELY rather than via a combined method, report 81445, '50, '55 for DNA analysis AND REPORT 81449, '51, '56 for RNA analysis.
In other words, as I am reading this, 81445/81449 are "not" classed as mutually exclusive, but 81455/81456 "are" classified as mutually exclusive.
Regarding the nuances of "separate method," CMS in its manual only quotes the same phrase the AMA uses: