Monday, November 25, 2024

CMS Posts New Lab Prices for CY2025

On Monday, November 25, 2025, CMS posted over 100 prices for new lab tests for CY2025.

This is the traditional cycle of posting proposed prices in September, taking public comment, and posting final prices around Thanksgiving week.   CMS will also release a complete fee schedule for lab tests for 2025 (including the 1500 ongoing codes plus the new ones) in the next ten days.

Find the CMS Clin Lab Fee Schedule page here:

https://www.cms.gov/medicare/payment/fee-schedules/clinical-laboratory-fee-schedule-clfs/annual-public-meetings

Scroll down for the heading, CLFS Test Codes Payment Determinations, and see CY  2025 Final Payment Determinations (ZIP for Excel).

https://www.cms.gov/files/zip/cy-2025-final-payment-determinations.zip

See a subscription article at 360dx.

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A few comments.

Actions in Overview

In total, 40 of 129 codes are in gapfill for 2025.

7 of the crosswalked codes were other than a single crosswalk.  One code was crosswalk to 0.5X, one code was crosswalked to 2X.  5 codes were crosswalked to a code stack, of which 1 was crosswalked to the sum of 4 codes (0430U=82103+83993+82653+84376).  I believe this was the 2nd time in 4 years (about 400 codes) that a fractional (0.5X) multiplier was used.  

In total, only 17 codes of the 129 varied from the September proposal (based on an automated Excel comparison.)  In 1 case, the test became an ADLT, in 2 cases, codes were deleted (3 codes dropped).   Of the remaining 14 codes, 8 were converted to gapfill (such as Alzheimer codes).  That leaves 7 codes that landed on a different crosswalk.   

CMS Looks to Code Text, Not "Under-the-Hood"

In an explanation that reiterates CMS looks at "code text" and not underlying variables, PLA code 0451U, a mass spec myeloma test from Mayo, remains crosswalked to 0077U.   CMS received complaints, but found that the complaints fell outside of the available code text.  CMS writes, "Finalize as proposed; the comments we received stated the specific tandem mass spectrometry technology is different.  However, looking at the CPT descriptors these differences are not outlined; meaning CMS cannot ascertain a difference.  In addition, commenters did not have an alternative crosswalk recommendation."   Similarly 0450U.

Additional Comments

Of very high interest to the Alzheimer community, a number of new codes for Alzheimer tests (Category I or 80,000-series codes) are now Gapfill rather than crosswalked to 83520 for only about $18.

A pre-eclampsia test (sFIT-1, PIGF), 0482U, was originally proposed CW to 81512 $69, but was shifted to 0243Ux2 ($64x2).   This is what Mayo had originally requested in June.

Two codes for special tests on whole-slide imaging (0512U, 0513U) were both crosswalked to 0220U, $706.

The Colosense FDA CRC screening test (stool), 0421U, asked for a crosswalk to Cologuard, 81528, $509,  and received it.   Cologuard Plus, 0464U, was initially offered a crosswalk to Cologuard, 81528.  However, in the final, Cologuard Plus got a more complex crosswalk, 81327x3 +82274.     This is $192x3 plus $16 or just short of $600.   
 
BillionToOne had 3 codes in play, 0449U (carrier screening x 5), 0486U (a methylation MRD test), and 0487U (an 84-gene LBx CGP test for driver oncogenes).   0449U shifted from gapfill to 81162 $1825 based on comments.  0486U remained as gapfill.  0487U was shifted from gapfill to 0409U [Lucence LBx] at $2919 based on public comment.