The MolDx program, and perhaps others, have LCDs making it difficult (not impossible) to bill for covered pathogen panels of >5 pathogens. That is, the code(s) for 3-5 pathogens are easily payable, a code for 6-11 pathogens is much more tightly controlled.
However, implementation of a 5-analyte cap was weak when faced with high multiples (10, 20, even 60) x 87798, a code which stands for "other pathogen, amplified probe." This code paid some $450M in CY2004. In some cases via doubtful labs, such as locating multiple 87798-intensive labs at the same addresses as doubtful home health or hospice services.
On Thursday, June 11, 2026, the HHS OIG announced a major program to audit providers of tests with "six or more pathogens." Read about it online. The audit program runs 2026-2028. Some labs have reported rising denials as early as March 2026 (here).
