Billing & Coding: CMS Reschedules PAMA Reporting & Adds New PLA Codes

July 15, 2022

This article originally appeared in G2 Intelligence, National Lab Reporter, July 2022, published on the G2 website on June 8, 2022.

Last month, the Centers for Medicare & Medicaid Services (CMS) announced quarterly changes affecting lab test reporting and billing under the Medicare Part B Clinical Laboratory Fee Schedule (CLFS). The changes take effect on July 1, 2022. Here are the two key CLFS changes your billing staff needs to know about.

1. Delay in PAMA Reporting

After two years of delay, the 2022 CLFS was supposed to include a Protecting Access to Medicare Act of 2014 (PAMA)-required 15 percent phase-in reduction in Part B reimbursements for Clinical Diagnostic Laboratory Tests (CDLTs). But on December 10, 2021, Congress passed legislation (the Protecting Medicare and American Farmers from Sequester Cuts Act) delaying application of the 15 percent cut for at least another year.

Under the CLFS final rule, labs and other reporting entities must give CMS certain private payor rate information for their component applicable laboratories. The data collection period was for claims for which final payment was received from January 1, 2019, to June 30, 2019. But CMS has reshuffled the reporting timetables in accordance with the delays in phasing in the 15 percent cuts. Specifically, it has based the next data reporting period of January 1, 2023, to March 31, 2023, on the original data collection period of January 1, 2019, to June 30, 2019. After the next data reporting period, there will be a three-year data reporting cycle for CDLTs that aren’t Advanced Diagnostic Laboratory Tests (ADLTs) (2026, 2029, etc.).

CMS has also extended the statutory phase-in of payment reductions resulting from private payor rate implementation through calendar year (CY) 2025. There’s a 0.0 percent reduction for CY 2021 and CY 2022, and the agency won’t reduce payment by more than 15 percent for CYs 2023-2025.

2. The New PLA Codes

In addition to the PAMA changes, CMS added nine new Proprietary Laboratory Analysis (PLA) CPT codes to the national Healthcare Common Procedure Coding System (HCPCS) file that will be recognized starting July 1, 2022. Medicare administrative contractors will decide how much labs in their jurisdiction will be reimbursed for the new PLA codes until a national price is set via the CLFS annual payment determination process.

Newly Listed PLA Codes, Effective July 1, 2022

Laboratory

CPT Code

Long Descriptor

Short Descriptor

Johns HopkinsMetagenomicNext-Generation

Sequencing Assay for Infectious Disease

Diagnostics, Johns Hopkins Medical

Microbiology Laboratory

0323U

 

Infectious agent detection by nucleic acid (DNA and RNA), central nervous system pathogen,metagenomicnext generation sequencing, cerebrospinal fluid (CSF), identification of pathogenic bacteria, viruses, parasites, or

fungi

 

IADNA CNS PTHGN NEXT GEN SEQ

3D Predict Ovarian Doublet Panel,

KIYATECInc

0324U

Oncology (ovarian), spheroid cell culture, 4-drug panel (carboplatin, doxorubicin, gemcitabine, paclitaxel), tumor chemotherapy response prediction for each drug

ONC OVAR SPHRD CELL 4 RX PNL

3D Predict Ovarian PARP Panel, KIYATECInc

 

0325U

Oncology (ovarian), spheroid cell culture, poly (ADP-ribose) polymerase (PARP) inhibitors (niraparib,olaparib,rucaparib,velparib), tumor response prediction for each drug

ONC OVAR SPHRD CELL PARP

Guardant360, Guardant Health,Inc

0326U

Targeted genomic sequence analysis panel, solid organ neoplasm, cell-free circulating DNA analysis of 83 or more genes, interrogation for sequence variants, gene copy number amplifications, gene rearrangements,

microsatellite instability and tumor mutational burden

TRGT GEN SEQ ALYS PNL 83+

Vasistera,

Natera,Inc

0327U

Fetal aneuploidy (trisomy 13, 18, and 21), DNA sequence analysis of selected regions using maternal plasma, algorithm reported as a risk score for each trisomy, includes sex reporting, if performed

FTL ANEUPLOIDY TRSMY DNA SEQ

CareView360,

NewstarMedical Laboratories, LLC

 

0328U

 

Drug assay, definitive, 120 or more drugs and metabolites, urine, quantitative liquid chromatography with tandem

mass spectrometry (LC-MS/MS), includes specimen validity and algorithmic analysis describing drug or metabolite and presence or absence of risks for a significant patient-adverse event, per date of service

DRUG ASSAY 120+ RX & METABLT

OncomapExTra, Exact Sciences,Inc,

Genomic HealthInc

0329U

Oncology (neoplasia), exome and transcriptome sequence analysis for sequence variants, gene copy number amplifications and deletions, gene rearrangements, microsatellite instability and tumor mutational burden utilizing DNA and RNA from tumor with DNA from normal blood or saliva for subtraction, report of clinically significant

mutation(s) with therapy associations

ONC NEO XOME&TRNS SEQ

ALYS

Bridge Women’s Health Infectious Disease

Detection Test, Bridge Diagnostics,

ThermoFisherandHologicTest Kit on Panther

Instrument

0330U

 

Infectious agent detection by nucleic acid (DNA or RNA), vaginal pathogen panel, identification of 27 organisms, amplified probe technique, vaginal swab

 

IADNA VAG PTHGN PANEL 27 ORG

Augusta Hematology Optical Genome Mapping,

Georgia Esoteric and Molecular Labs, Augusta

University,Bionano

0331U

Oncology (hematolymphoidneoplasia), optical genome mapping for copy number alterations and gene rearrangements utilizing DNA from blood or bone marrow, report of clinically significant alternations

ONC HL NEO OPT GEN MAPPING

Source: CMS Manual System, Pub 100-04 Medicare Claims Processing, Transmittal 11398

Note: All codes are listed as TOS 5

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This article originally appeared in G2 Intelligence, National Lab Reporter, July 2022, published on the G2 website on June 8, 2022.

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