Responding to longstanding industry criticisms, the Centers for Medicare & Medicaid Services (CMS) has announced a number of changes to the Healthcare Common Procedure Coding System (HCPCS) coding process for 2019.  Most of the new policies are intended to increase transparency regarding CMS HCPCS coding decisions.  The one substantive change of note is that CMS is eliminating its requirement that items other than drugs and biologicals demonstrate 3% market volume (although CMS will still require applicants to submit specified marketing data to support a new code).  With regard to improving transparency and clarity in the HCPCS decision process, CMS is:

  • Clarifying and updating web-site guidance associated with the application process
  • Developing a new electronic application process (which will be beta tested with a limited number of stakeholders in the 2019 cycle)
  • Providing more detailed responses to applications
  • Allowing remote participation in HCPCS public meetings
  • Archiving past years’ files/decisions on the HCPCS website

According to CMS, its changes to the HCPCS process seek to “facilitate the adoption of new technologies while balancing the burden on payers and providers and considers program needs.”  We would note, however, that these modifications to the application process do not address broader concerns that CMS’s standard for new codes is too rigid, particularly for medical devices, which results in insufficiently-granular codes and imposes a barrier to adoption of new medical technologies.

CMS is currently accepting applications for HCPCS codes that would go into effect January 1, 2020; the application deadline is January 7, 2019.