The Association for Molecular Pathology (AMP) keeps an active and up-to-date page for its public comments (here). Here, I link to three letters in which they raise concerns about gapfill pricing, CLFS crosswalk pricing, and MAC consolidation.
###
AMP on GAPFILL
Recently, they commented on final Gapfill prices at CMS, especially for CGP (comprehensive genomic profiling) and LBx codes. (Final gapfill prices can be commented upon, but rarely change). Their letter includes a comprehensive table of the numbingly-long list of codes related to CGP.
They also raise concerns with the opaqueness of the gapfill process in general.
Regarding the MolDx EPM (Equitable Pricing Model), AMP writes, "It is not appropriate for proprietary methods to be used in this public process for establishing payment rates for a federal government program meant to serve the American people. Moreover, MACs following the Equitable Pricing Model also do not divulge the specific information that serves as the input into the Model. Considering these issues together, the lack of transparency makes it impossible for the public to meaningfully engage in the establishment of payment rates for testing services provided to Medicare beneficiaries."
>> I submitted a FOIA request for the EPM, and CMS responded they had obtained and filied a several-page document about it from the MAC, which they declined to release.
Find the AMP letter on gapfill here:
https://amp.org/AMP/assets/File/advocacy/AMPComments-MACFINALGAPFILLdeterminationsFINAL.pdf
AMP on CROSSWALK / SUMMER MEETINGS
AMP also commented on several of the 100-plus codes in this summer's pricing meeting. The comments are in regard to proposed CMS prices released in late September. They focused on a few infectious disease molecular codes:
https://amp.org/AMP/assets/File/advocacy/AMPcommentsonCY2025PrelliminaryDeterminationsFINAL.pdf
[See below]
AMP on MAC CONSOLIDATION
Finally, I noted on this blog in September that CMS was officialy considering MAC consolidation, as well as shifting the MACs to 10-year contracts (here). AMP also has a position on that. They include comments on inconsistencies and problems with how different MACs currently make decisions. They write, "We are generally concerned that MAC consolidation would grant additional work to MACs that have been less successful with working with organizations like AMP."
###
If ACLA releases a public comment letter on these topics, it will appear here.
###
AI Corner. AMP's comments on two crosswalks were somewhat complex. I asked for a Chat GPT simplification here, if of interest.
#
AMP is recommending that CMS adjust its proposed crosswalks for two key CPT codes to ensure fair pricing based on the specific resources used for these tests:
CPT Code 87626 (HPV Detection): AMP argues that CMS's suggested crosswalk to 87624 undervalues 87626's complexity. Unlike 87624, 87626 detects multiple high-risk HPV genotypes simultaneously using different primers and probes within one assay, requiring additional bioinformatics for analysis. AMP suggests crosswalking 87626 to 87624 + 87625, or alternatively, to 87801 if CMS remains concerned about redundancy.
CPT Code 87513 (H. pylori Detection with Antibiotic Resistance): CMS’s crosswalk recommendation to 87150 misses the more intensive requirements of 87513, which performs multiplex PCR to detect both H. pylori and antibiotic resistance. AMP proposes a crosswalk to 87640 + 87641 to better reflect the additional work and resources required, pointing out that CMS previously applied a similar logic to other comparable tests.
These adjustments, AMP contends, would more accurately reflect the actual work involved in these diagnostic tests, promoting consistent and fair pricing across the Clinical Laboratory Fee Schedule
