Last fall, CMS proposed to create two cancer modifiers as two-letter HCPCS codes, for local versus metastatic cancer. (See my February blog here).
CMS has published its final results based on that December 2025 code cycle, and CMS will NOT procede with the cancer modifiers at this time.
Find the "Final Decisions" PDF here, and see page 144 "Next Generation Sequencing."
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CMS Final HCPCS Coding Determination
We appreciate the comments provided in response to CMS’ published preliminary determination. After consideration of the comments we received, CMS is revising its preliminary coding determination. Based on the concerns that were raised by stakeholders, CMS will not be pursuing the implementation of the proposed modifiers at this time.
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Public comment
The Association for Molecular Pathology (AMP) expressed concerns about CMS’ preliminary determination. The primary concern centers on the administrative burden these modifiers would place on laboratories. AMP emphasized that laboratory professionals, while integral to patient care teams, do not directly manage patients or determine cancer staging. These modifiers would require laboratories to obtain and verify detailed staging information. This would be operationally impractical and could delay access to critical genomic information needed for treatment decisions. They stated that these modifiers could provide payers with additional mechanisms to inappropriately delay or deny reimbursement.
The commenter recommended that CMS delays implementation of these modifiers and clarify that they apply only to somatic testing, not NGS germline testing, as current coverage policies for germline testing do not restrict coverage based on cancer stage. AMP expressed interest in working with CMS to reopen National Coverage Determination 90.2 to align coverage criteria with current advancements in the field and welcomes further discussion to provide additional technical and clinical insights.
