There is an impending boom of new capabilities which will arrive as digital pathology plus AI or machine learning.
There will be an old fashioned collision: How will the coding and reimbursement system handle them?
Background - PLA
From about 2021-2024, the AMA CPT made about a half-dozen codes for such services under the PLA coding system - Proprietary Laboratory Analyses. However, the last digital pathology code under PLA appears to date back to July 2024. Since then, I've seen dig path codes applied for (AMA publishes quarterly applicants), but they vanish without being finalized (AMA publishes final quarterly codes).
Background - AMA Digital Medicine
Enter the AMA Digital Medicine Payment Advisory Group DMPAG. They created Appendix S, an initial AMA CPT template for digital medicine or AI-medicine.
September 2025 at AMA - "Tab 94"
At the September 2025 AMA CPT meeting, the DMPAG will unveil a new proposal which will have massive impacts on coding and reimbursement for digital pathology. It's known as "TAB 94."
- While you can only access Tab 94 documents to review under confidentiality, I did hear an AMA talk last week at a lab conference, about Tab 94, where Tab 94 was presented without any disclosure requirements. Still, I'll only briefly allude to Tab 94 and I'll give you instructions step-by-step how to get it yourself.
Tab 94 would create a new section of AMA CPT - not Category I, nor Category III, nor PLA. It will hold services from any area of medicine - such as radiology, cardiology, and pathology - based on computer output from a digital algorithm. It is proposed to be called CMAA - Clinically Meaningful Algorithmic Analyses. Services would require FDA approval.
Questions You Might Ask
Who are the stakeholders here? Specialty labs like Artera AI? Large genomic labs with a big push in AI services too - such as Tempus? Lab stakeholder organizations (think CAP, ACLA?) Other very large stakeholders, like AdvaMed (radiology, cardiology) and AdvaMed DX (diagnostics)? And PHRMA (as FDA digital pathology tests become companion diagnostics for FDA drugs). Should cardiology-radiology services have one AMA category (always requiring FDA) and pathology another (allowing either FDA or CLIA options)?
Finding Tab 94 - Mini Approach
I think you should be able to find Tab 94 by going to this link, which may require you to get an AMA account using your email before proceeding.
https://cptsmartapp.ama-assn.org/ipdashboard
Be sure you are in the "Interested Party" half of the above website, scroll down, click forward, find Tab 94 and request to review.
Finding Tab 94 - Step by Step Approach
I wouldn't be surprised if just finding the AMA Tab 94 download button is confusing to some. I also put online detailed instructions step by step.
https://brucedocumentblog.blogspot.com/2025/08/ama-pla-and-tab-94.html
