Attached are the ASM’s recommendations for payment determinations for new Current Procedural Terminology (CPT) codes to be included in the 2021 Medicare CLFS. We have limited our comments to those tests that affect our constituency, and our recommendations are based on the consensus of ASM’s Subcommittee on Coding and Reimbursement, which reviewed the codes to be addressed and provided input. Our comments include the following information:

• New test code(s) and descriptor
• Recommendation (cross-walking or gap-fill) and data on which recommendation is based
• Rationale for recommendation

We greatly appreciate the opportunity to comment. If additional supporting materials are required, we will provide them on request.
The ASM is one of the largest single life sciences associations, with over 32,000 members worldwide. Its members work in environmental, educational, research, industrial and government settings on issues such as the prevention and treatment of infectious diseases, laboratory and diagnostic medicine and food and water safety. The ASM’s mission is to advance the microbial sciences as a vehicle for understanding life processes and to apply and communicate this knowledge for the improvement of health and environmental and economic well-being worldwide.

Many ASM members have primary involvement in clinical laboratory medicine including individuals directing clinical microbiology, immunology and molecular diagnostic laboratories, individuals licensed or accredited to perform such testing, industry representatives developing laboratory products for use, and researchers involved in development and evaluation of new technologies. Therefore, the ASM has significant interest in the process of establishing reasonable reimbursement for medically necessary laboratory testing to ensure quality patient care for Medicare beneficiaries.

Sincerely,

Omai Garner, Ph.D., D(ABMM)
Chair, Clinical and Public Health Microbiology Subcommittee on Coding and Reimbursement