Thursday, March 26, 2026

AI, Advanced Software, and AMA CPT Policy: Deadline March 31: Appendix S for Upcoming CPT Meeting

 For several quarters, AMA CPT has been debating major amendments to the AMA CPT "Appendix S," which may have enormous implications for how AI- or software-dominant healthcare services are reimbursed.

At the upcoming AMA CPT meeting in Chicago [virtual registration still available], a new round of revisions to Appendix S will be debated.  You can sign up now to read the current revisions and make public comment.  Debate was vigorous at the AMA CPT last September and this past February.  

Revisions to Appendix S may be followed by creating a new coding section called "CMAA," Clinically Meaningful Algorithmic Analyses.   

The deadline to comment is Tuesday, March 31.

My main concern is, they'll bring in policies adapted for radiology, cardiology, etc, and they may be a poor fit for genomics, which makes universal heavy use of extremely sophisticated software including AI and which already does not require "physician work" as its main input.

Here's how to comment:

First, go to the online PDF agenda for the April CPT meeting:

https://www.ama-assn.org/system/files/cpt-panel-may-2026-agenda.pdf

Click on the boldface link for INTERESTED PARTY COMMENT.  This should take you to AMA website here, but click on the PDF's link if the one below doesn't work.

https://cptsmartapp.ama-assn.org/ipdashboard

You may need to email register with AMA to access AMA functions like this comment dashboard.

When you get to the AMA CPT Smart App, be sure and click the tab near the top for "INTERESTED PARTY" view. Scroll down to bottom.


Note that for Tab 67, Appendix S, it sends you to the "Ballot" option (far right column) which is where you find the actual markup version of a new Appendix S.

Use the progress button near the bottom to scroll ahead to Agenda 67 (Appendix S).


So you've tapped Interested Party Portal, advanced to where you find Appendix 67.   There are four columns:

  • IP Interested Party Access (to CPT application and supporting documents like publications)
  • IP Comment (you get a fixed form on which to write your comments)
  • View Comments
  • BALLOT (in the case of Appendix S, you gotta get this, the actual 4-page appendix)
Appendix S is damn hard to read - it's nearly entirely fields of struck-out text and inserted text from beginning to end.   But it's important.

See snapshot of the heavy edits throughout: