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Lab Organizations Ask CMS to Withdraw Coding Guideline Updates

NEW YORK (360Dx) – A group of clinical laboratory and pathology organizations has written to the Centers for Medicare & Medicaid Services expressing concern with recent changes to agency polices around test billing practices.

In a letter dated March 17, the organizations express concern about updates to the Pathology/Laboratory Services section of the National Correct Coding Initiative (NCCI) Policy Manual and the Policy Manual for Medicaid Services that took effect January 1, 2019 and which they wrote "were issued without notice or stakeholder input," and which "will be highly disruptive to coding and payment for clinical laboratory and pathology testing services."

At issue are recent updates to the Pathology/Laboratory Services section of the National Correct Coding Initiative Policy Manual for Medicare Services and corresponding updates to the Policy Manual for Medicaid Services.

More specifically, the lab groups object to changes to CMS' guidance around what healthcare common procedure coding system (HCPCS) and current procedural terminology (CPT) codes laboratories should report for particular procedures, with the updated guidance instructing labs to report "only a single HCPCS/CPT code" even in cases where a laboratory procedure produces multiple reportable test results.

According to the industry organizations, these instructions could make it more difficult for claims processors to determine what exact tests were performed, increasing the claims processing burden for the Medicare and Medicaid systems and delaying payment to lab providers.

In one example, the industry groups cite a new instruction stating if a lab procedure "produces multiple reportable test results, only a single HCPCS/CPT code shall be reported for the procedure. If there is no HCPCS/CPT code that describes the procedure, the laboratory shall report a miscellaneous or unlisted procedure code with a single unit of service."

According to the letter, the new instruction is "overbroad and unclear," and what constitutes a "laboratory procedure" is unclear. This may lead to reports that violate the American Medical Association's guidance to use specific CPT codes.

The group requested that CMS withdraw the updates "and work with stakeholders to address concerns the Agency may have about clinical laboratory and pathology billing processes while avoiding problematic unintended consequences."

Among the groups signing the letter are the American Association for Clinical Chemistry, the American Clinical Laboratory Association, the College of American Pathologists, and the Association for Molecular Pathology, and others.