In the past month two different people have asked me about the
MOLDX statement of work. It's online at a
federal RFP website, and I've clipped it here on my documentation
blog.
Features of the SOW include:
- pricing of tests not priced on the CLFS,
- maintaining a test code registry (e.g. Z codes), and
- providing standard formats for evidence and conducting systematic evidence review.
- MolDX is also to advise CMS on new national edits.
- There's an interesting section that very clearly authorizes "coverage with evidence development" or "coverage with data development," although LCDs from MOLDX do not currently use that.
MOLDX has some policies which don't trace as easily to the SOW, which I discussed
here. These included
(1) altering prices of codes that do have CLFS prices,
(2) not using CMS CPT codes for two or more tests, because they become "panels," and
(3) employing
local edits (such as blocking payment of 81433 when 81432 is used) that have
not been migrated to "national" edits in the public CCI system.
Update: Around December 1, they stopped using Mod 22 to up-price certain codes already priced on the CLFS.
