August 2012 Newsletter
AMA to Delete “Stacked” Codes;
CMS to Price Molecular Pathology Procedure Codes
The American Medical Association (AMA) has announced plans to delete “stacked” codes for molecular pathology procedures (MPP) from the CPT 2013 codebook, allowing the test-specific MPP codes introduced in 2012 to become the standard. The expected deletion of stacking codes has put pressure on the Centers for Medicare & Medicaid Services (CMS) to establish prices for the new MPP codes by January 1, 2013.
When the MPP codes were introduced in 2012, CMS delayed pricing them to gather more information on what appropriate reimbursement levels should be. As a result, stacking codes remained in effect for both government and non-government payers. With the deletion of stacking codes, CMS must assign prices to the MPP codes in its 2013 fee schedules. The question is, which fee schedule should the MPP codes be priced on, the Physician Fee Schedule (PFS) or the Clinical Laboratory Fee Schedule (CLFS)? Currently, all the stacking codes are priced on the CLFS (one is priced on both the CLFS and PFS), but there is debate in the molecular pathology community about whether some of the new MPP codes ordinarily require physician work and should be paid through the PFS.
In July 2012, CMS proposed that all 101 MPP codes be priced on the same fee schedule, either the PFS or CLFS, because pricing the codes on two different fee schedules would result in different payment rates for similar procedures. In addition, CMS proposed that if the MPP codes are added to the PFS, Medicare contractors should price them “because we [CMS] do not believe we have sufficient information to engage in accurate national pricing and because the price of tests can vary locally.” To help decide which fee schedule to use, CMS continues to consider input from important stakeholders, such as the College of American Pathologists, the American Clinical Laboratory Association, and the AMA.
The AMA is expected to make the following changes to the CPT 2013 codebook with regard to molecular pathology procedures:
- Stacking codes 83890–83914 and their related guidelines will be deleted.
(Related guidelines may include array codes 88384–88386 and genetic test modifiers, but it is not clear if these will be deleted.) - A new Category I unlisted MPP code (814XX9) will be introduced to describe tests that do not have a specified code.
- Tier 2 codes 81400, 81401, and 81403–81408 will be revised to include more tests that fit the criteria described by these codes.
- For code 81403, the number of exons in the KRAS test will be changed from two to three.
- To report adenomatous polyposis coli analysis, new codes AXXX2, AXXX3, and AXXX4 will be added.
These changes to the CPT 2013 codebook are not guaranteed, as nothing is finalized until just prior to publication.
For updated information on how the MPP codes will impact laboratory reimbursement, check future issues of Q-Tips and bulletins on the Quadax website.