In today’s Federal Register, the Centers for Medicare & Medicaid Services (“CMS”) announced the dates, time and location of the Healthcare Common Procedure Coding System (“HCPCS”) public meetings for calendar year 2014. CMS hosts these meetings to discuss the preliminary coding and payment determinations for all new public requests for revisions to the HCPCS. Ensuring that appropriate HCPCS codes (for some drugs, these are referred to as “J-Codes”) are available for products can be critical to successful commercialization in the United States. These codes are used by government, as well as commercial payors, for classifying items and services and assigning reimbursement rates.
The following meetings were announced (all meetings are scheduled from 9 a.m. to 5 p.m. Eastern Daylight Time):
|Topic||Meeting Date||Deadline for primary speaker registration and to submit materials and writings to be used in support of an oral presentation||Deadline for all other attendee registration (no foreign nationals)||Deadline to request special accommodations|
|Drugs/Biologicals/ Radiopharmaceuticals/ Radiologic Imaging Agents||5/20/14-5/21/14||5/6/14||5/14/14||5/13/14|
|Supplies and “Other”||5/28/14||5/14/14||5/21/14||5/21/14|
|Durable Medical Equipment (DME) and Accessories; and Orthotics and Prosthetics (O&P)||6/3/14||5/21/14||5/27/14||5/27/14|
In addition, CMS will accept written comments, if received by the date of the meeting at which the code request is scheduled for discussion. Meeting attendees may also submit their written comments at the meeting. All meetings will be held in the main auditorium of the central building of CMS at 7500 Security Boulevard, Baltimore, Maryland.
CMS permits three types of coding revisions to the HCPCS to be requested:
1. That a permanent code be added
“When there is not a distinct code that describes a product, a code may be requested (1) if the FDA allows the product to be marketed in the United States and (2) if the product is not a drug, the product has been on the market for at least 3 months; if the product is a drug, there is no requirement to submit marketing data; and (3) the product represents 3 percent or more of the outpatient use for that type of product in the national market. If a request for a new code is approved, the addition of a new HCPCS codes does not mean that the item is necessarily covered by any insurer. Whether an item identified by a new code is covered is determined by the Medicare law, regulations, and medical review policies and not by the assignment of a code.”
2. That the language used to describe an existing code be changed
“When there is an existing code, a recommendation to modify the code can be made when an interested party believes that the descriptor for the code needs to be modified to provide a better description of the category of products represented by the code.”
3. That an existing code be deleted.
For more information on the HCPCS coding process, see: http://www.cms.gov/Medicare/Coding/MedHCPCSGenInfo/. Agendas for the public meeting will be published approximately four weeks in advance of each meeting at http://www.cms.gov/Medicare/Coding/MedHCPCSGenInfo/HCPCSPublicMeetings.html. Companies with new products and/or who believe that previous codes have not adequately addressed their product(s) for reimbursement purposes should strongly consider attending and/or submitting comments to the appropriate meeting.