Just over a year ago, in November 2018, CMS released a few sometimes-bizarre new rules for coding of panel testing and especially genetic test panels (see original blog and links here and here). This led to ongoing letters and meetings between ACLA and others for many months in CY2019. See e.g. a subscription article on the topic in Dark Report in April 2019 here.
Without much fanfare, CMS released some revisions to its edits in November 2019 for Calendar 2020. The revisions are in Section F (Molecular Pathology) of Chapter 10 of the National Correct Coding Edits Policy Manual. (Download via link "NCCI Policy Manual Effective January 1, 2020" at this website here.)
ACLA has already publicly complained, in December 2019, about some of the NCCI language. See online here.
You should read the ACLA letter for yourself. I have a few comments below that may be a "glass half full" view of some of the edits, at least in Sections 7,8,9. ACLA thanks CMS for some of the edits I'll be highlighting next, while complaining that elsewhere in the NCCI manuals there remains adverse language. In particular, there are arguments that NCCI language would cause mass overuse of unlisted codes.
Mostly Favorable Small Revisions to Genetic Edits
Whereas Section 7 originally said that Tier 1 or Tier 2 MoPath codes "shall not" be reported with a genomic sequencing procedure (e.g. panel), it now says that those codes "should not, in general, be reported" with a GSP. If procedures are reported together, they should both be medically reasonable and necessary.
Whereas Section 8 originally said that NGS procedures must be reported by a single CPT code (e.g. GSP) or 81479 (unlisted procedure), the text now says that if no single code accurately describes the NGS procedure, it MAY be reporting with 81479 or MAY be reported with multiple individual CPT codes "when medically reasonable and necessary."
Whereas Section 9 blocked some pairs of MoPath codes from being reported together, it now says that code-to-code edits are codes that "should not, IN GENERAL, be reported together." Again, it is restated for the third time that if codes are reported together they must both be reasonable and necessary.
On the whole, improved.
NCCI labels changes in red, so it's easier to see additions than deletions. I didn't note any other changes that seemed significant, but you should check the manual yourself for your own area of interest.
I've put a direct cloud link to a January 2020 version of the Pathology policy chapter in the cloud here. However, the CMS webpage linked above should be checked for any possible updates.
