MolDx Posts Complex Billing & Coding Article for its Complex PGX LCD

A week ago, I wrote an article about the unusually novel and complex LCD that MOLDX produced this summer to cover both single gene and panel PGX testing - my article here.

At that time, I hadn't yet seen the recently posted novel and complex Coding and Billing Article, A58315, which is a new attachment to PGX LCD L38294.

Find the coding and billing article here.   (Find my archival cloud copy here).'

UPDATE:  See also MOLDX form M00156, an Excel spreadsheet that is used to describe your PGx panel test (genes, alleles, etc).  Note that you should refer to the PGX LCD for requirements for allele minimums.  

I haven't fully got my head around this yet, but MolDx has been saying it plans to price all PGx panels at one average rate.   MolDx allows you to bill a panel if 2 or more genes are necessary, so it sounds like they would pay the same whether a particular patient merited 2 genes or 4 genes under the LCD's rules.  

MolDx and MACs have been "fighting code stacking" for years, mostly by posting and re-posting testy articles or rules, without a lot of real progress, so we'll say how this new effort turns out.  MolDx management writes policies, but the implementation (or complete lack thereof) and claims processing depends on the local MACs that are part of the MolDx constellation.