Header: For AMA CPT Meetings, AMA will now released full minutes (100-pages-plus.)
The AMA has two major reimbursement-related committees: the CPT Editorial Panel and the Relative Value Update Committee- the RUC.
For years, detailed meeting minutes of the RUC have been online. In contrast, AMA CPT posted only an abbreviated "Summary of Panel Actions" - e.g. code applications that were voted in, rejected, or postponed.
Now, AMA CPT posts both the "Panel Actions" and also detailed "Minutes" (over 100 pages) for CPT meetings.
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The updated web page for editorial actions says, "To provide transparency in the decision-making process, meeting minutes and voting results, along with the summary documents, are included on this page for the last five years." However, as of now, I only see meeting minutes for September 2027 (Minneapolis CPT).
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Find the CPT page here:
Find the RUC page here:
https://www.ama-assn.org/about/rvs-update-committee-ruc/ruc-recommendations-minutes-voting
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Tab 19 - Renal denervation for severe hypertension. I was happy to see this final passed. The debate was extensive and many panelists seemed critical this was read for Category I. The minutes show the exact new finalized code(s) and in this case, the matching deletion of its Category III code (0338T, 0339T).
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Tab 94 - Revisions to the Category I (and Category III and MAAA) pathology & laboratory application, which is different that the Cat I, Cat III application for all other services. See page 109ff for the typed version of the pending new online form.
At the link, you can see the whole minutes and the 20-plus pages about Tab 94. I asked Chat GPT to extract an outline of the new lab application. This is for the eye, only; plan your application with the AMA source materials and online application portals.
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AMA CPT Category I, III Application — Pathology/Laboratory
Summary of Application Questions (September 2026 Revised Form)
The AMA Pathology/Laboratory Code Change Application (CCA) applies to Category I laboratory codes, Category III codes, and Administrative MAAA codes. The September 2026 revisions introduce specific requirements for AI-enabled procedures.
The following is a condensed outline of the application. Numbering is added for this summary rather than reproduced from the electronic form.
I. Application Rationale and Proposed Code
- Rationale: Why is a new code necessary?
- Code Placement: Category I, Category III, or Administrative MAAA?
- Proposed Descriptor: What specific procedure and code language are proposed?
- Existing Codes: What existing codes describe related procedures, and why are they inadequate?
- Major Differences: How does the proposed procedure differ from existing CPT services?
- Integral Services: What other procedures are included in the proposed service and should not be separately billed?
- Concurrent Applications: Are related applications being submitted elsewhere in CPT, including PLA?
II. AI-Specific Information (New Section)
- AI Identification: Does the software perform functions beyond ordinary data processing?
- Data Flow: Describe the inputs, processing steps, quality checks, and outputs; provide a workflow diagram.
- Level of Output: Is the software assistive, augmentative, or autonomous under CPT Appendix S?
- Classification Rationale: Explain and validate the selected AI classification.
- FDA Documentation: Provide FDA authorization, proposed indications, or other regulatory documentation.
- Generalizability: Describe training datasets, population representativeness, and real-world surveillance.
- Social Bias: Discuss potential algorithmic bias and mitigation.
III. Clinical Utilization and Data Collection
- Clinical Trials: Identify ongoing or proposed trials and relevant precedent assays.
- Annual Test Volume: Report current volume and supporting data.
- Performing Laboratories: Number of laboratories performing the test.
- Future Utilization: Expected changes in adoption and clinical use.
- Distinct Service: Is the procedure separately ordered by clinicians?
- Current Coding: Identify existing CPT/HCPCS codes used for the test.
- Coding Inadequacy: Explain why current codes lack sufficient specificity.
- Clinical Conditions: Identify diseases and indications.
- Disease Prevalence: Incidence or prevalence of relevant conditions.
- Biomarker Association: Evidence establishing the biomarker–disease relationship.
- Clinical History: How many years has the procedure been performed?
- CLIA Classification: High complexity, moderate complexity, or waived.
- Coding Redistribution: What percentage of existing coded services would migrate to the proposed code?
- Clinical Guidelines: Relevant professional guidelines and recommendations.
- Quality Measures: Whether the test is incorporated into national quality measures.
IV. Physician Services and Clinical Procedure
- Performing Specialties: Specialties performing the test or using its results.
- Site of Service: Hospital laboratory, independent laboratory, physician-office laboratory, etc.
- Clinical Vignette: Typical patient, clinical indication, specimen, and intended use (75-word limit).
- Vignette Consistency: Does the patient vignette match published study populations?
- Procedure Description: Step-by-step summary of specimen processing, testing, analysis, interpretation, and reporting.
- Procedure Consistency: Does the procedure match that described in the supporting literature?
V. Supporting Documentation
- FDA Status: Market authorization, indications for use, and product insert.
- FDA Safety and Effectiveness: FDA SSED or other relevant regulatory documentation.
- Laboratory SOP: Standard operating procedure, particularly for laboratory-developed tests.
- Intended Use: Clinical purpose and indications.
- Test Principle: Scientific and analytical methodology.
- Service Components: Specimen preparation, digitization, algorithmic analysis, interpretation, and proprietary elements.
- Limitations: Analytical and clinical limitations.
- Sample Reports: Redacted examples of all relevant clinical results, including algorithmic output separately from the final laboratory report.
- Population Applicability: Relevance of foreign clinical studies to U.S. populations.
VI. Scientific Literature
- Supporting Publications: Generally three to five peer-reviewed articles establishing clinical validity and utility.
- Disease Association: At least one publication addressing the biomarker–disease relationship.
- Analytical Performance: Supporting methodological evidence when applicable.
- Evidence Classification: Study design, level of evidence, and number of patients.
- Relevance Statements: Explanation of how each publication supports the proposed code.
- Conflicting Evidence: Identification and discussion of relevant contradictory publications.
VII. Administrative Requirements
- Stakeholder Notification: Relevant medical specialty societies and interested parties.
- Application Attestations: Confidentiality, conflicts of interest, copyright, and compliance.
- Additional Comments: Other information relevant to the application.
