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  • 1.  Coding and Reimbursement

    This message was posted by a user wishing to remain anonymous
    Posted 08-Sep-2017 09:13
    This message was posted by a user wishing to remain anonymous

    Looking for a good, inexpensive resource to learn more about the PROCESS required for a new clinical lab IVD to obtain coding and reimbursement. For instance, focus on obtaining CPT code first or focus on obtaining a HCPCS code first? Can only find application information at CMS.gov for a level II HCPCS, but what if I am a level I with no CPT? Understanding the requisite steps and timing for before, during and after 510(k) review would be helpful. Thanks!!


  • 2.  RE: Coding and Reimbursement

    Posted 10-Sep-2017 07:09
    ​It wasn't clear from the question what you are looking for.

    If you hope to get a new code established for your device, please be aware that this takes years and a significant amount of data for justification. Plus your device will need marketing data to show that you've captured at least 3 % of the available market. This information is rarely available for a recently cleared device.

    The first place to start would be doing a search here:
    DME Classification System

    try to see if similar devices already have a HCPCS code. If so, the process is fairly simple. You only need to submit a "Coding Verification Request" to have your device included in an existing code.

    ------------------------------
    Jean Bigoney PHD, RAC
    Managing Member
    Nu Device Consulting LLC
    Murphy NC
    United States
    ------------------------------



  • 3.  RE: Coding and Reimbursement

    This message was posted by a user wishing to remain anonymous
    Posted 11-Sep-2017 09:34
    This message was posted by a user wishing to remain anonymous

    Thanks very much for the response. I am still trying to understand process, so the question is aimed at understanding the steps I must follow. Do I have to go get a HCPCS code first through CMS, and then go get the CPT code from AMA which will take the 3 years and require all the evidence?
    My IVD is one that is aimed at one therapeutic drug that is similar to an IVD for a different therapeutic drug that already has a CPT code, but I have been cautioned by an external party that new HCPCS and CPT codes should be obtained for the new device because using those for the similar device is too risky, and I don't know where to start in doing that.
    Interestingly, when I search that similar device code (I used the CPT code which is presumably the HCPCS code) on the DME link that you provided, it is not found, so I am not sure what that means?



  • 4.  RE: Coding and Reimbursement

    Posted 12-Sep-2017 06:37
    ​This sounds very complex, possibly too complex to answer on a forum such as this one.

    It is the new HCPCS code that requires market data and proof of a market share of at least 3 %. I do not know about CPT codes.

    Also, the link I posted is only for HCPCS codes, not CPT codes. Those are not the same things. CPT codes are used to coding procedures, HCPCS codes are used for reimbursement of durable medical goods supplied to patients,

    I suggest you try searching using the name of a competitor device. Having an external party advise you to get your own HCPCS code is all well and good, but that will cost a lot of money and typically takes ten years. I advise clients to use an existing HCPCS code if at all possible and make sure that the reimbursement rate is consistent with anticipated cost.

    ------------------------------
    Jean Bigoney PHD, RAC
    Managing Member
    Nu Device Consulting LLC
    Murphy NC
    United States
    ------------------------------



  • 5.  RE: Coding and Reimbursement

    Posted 13-Sep-2017 07:55
    It is very complicated.   A regulatory process like going through FDA but with few published rules, the use of a informally deputized American Medical Association (AMA) that acts as a quasi-governmental authority but with little due process or transparency-- often described as a star chamber.  FDA is amazingly great compared tho CMS and AMA.  You will need to learn the concepts of coverage, coding and payment.  You need professional assistance.  Try J.D. Lymon & Associates in the Twin Cities, Minnesota. 

    Mark DuVal, J.D., FRAPS



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