Since comments closed on March 31, I've highlighted several groups that commented, such as ACLA and the BCBS Association. Both supported "nationalization" of MolDx, a topic on which HHS was seeking input. (ACLA had some guardrails, though).
College of American Pathologists (CAP) posted its comments, 7 pages long. A substantial proportion of the comment recounts problems that CAP sees with MolDx, including the whole Z-code system.
Find the CAP comments here:
https://documents.cap.org/documents/FINAL-CRUSH-RFI-Comment-v.5.pdf
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The national Medicaid medical directors' organization NAMD submitted lengthy comments on crush, with no mention of genetic test fraud, suggesting they don't view it as a problem and have little difficulty in avoiding or preventing it. (Here). This makes Medicare Part B's billion-dollar fraud problems in Texas and Florida even more embarassing.
