Industry CPT Coding Assistance
AGA, ACG,ASGE Industry Coding and Reimbursement Declaration
The American Gastroenterological Association (AGA), the American College of
Gastroenterology (ACG) and the American Society for Gastrointestinal Endoscopy
(ASGE) have an active role in establishing and/or revising CPT® codes
for new/existing procedures relevant to the practice of gastroenterology. The
three societies coordinate this as a cooperative effort. In recent years, the
societies have introduced over 60 codes with matriculation through the CPT
Editorial Panel, RBRVS Update Committee (RUC) and Practice Expense Subcommittee
process, with assignment of reimbursement values by the Centers for Medicare and
Medicaid Services (CMS). Through our direct interactions with CMS, C-codes and
G-codes (CMS-issued procedure codes) have been established for new technologies
that require more immediate coding for Medicare beneficiaries than possible with
the traditional CPT/RUC process. The societies also provide comment to CMS
regarding APC (hospital outpatient payment classification) rates and other
The ability to secure new codes has evolved through early communication with
industry and provision of frequent guidance on issues pertinent to
reimbursement. Often, these aspects are not inherent in the processes involved
in FDA approval. The data necessary for optimizing reimbursement for
practitioners should be considered when developing efficacy and safety studies
to support widespread clinical use of new technology. These components of the
process are aspects for which the gastroenterology societies are able to provide
To facilitate communication with industry, we have outlined the requisite
information our organizations need to assist in the reimbursement process. We
recognize that the phase of development of technology will vary and not
accommodate the ability to provide all of this information initially. For these
projects, we are able to provide guidance as the development matures. However,
all should recognize that ultimately this information is needed when attempting
to procure a category I CPT® code and the reimbursement associated
with its use. The societies are prepared to assist companies to proceed along
these lines at any step of their development. To prepare our representatives
with the necessary information to support new procedures, we solicit input from
individuals who are not directly involved in the development process but who
have expertise in the area under consideration.
Although this critical review of the new technology may appear onerous, the
CPT and RUC process will engage in this debate and our organizations recognize
this preparation facilitates the best proposal. The following reflect our
guidelines for assisting with this process.
the AMA calendar of CPT and RUC meetings and deadlines.
Requested Information from Industry to Facilitate Procurement of
- A brief (five pages or less) executive summary of literature supporting the
clinical utility of the device/procedure. Copies and reprints of articles and
abstracts should accompany the submission. For less mature technologies, a
descriptive narrative explaining the technology and preliminary investigation is
- A statement regarding which authors in quoted literature have financial ties
(stock ownership, consulting fees, research support, advisory board,
honorariums, venture capital / hedge fund) with the company. The presence of a
financial relationship does not preclude utilization of the data that the
investigator is responsible for.
- A review of safety data regarding the device/procedure.
- A CPT
application should be completed by the requestor as completely as possible
including peer-reviewed, published literature in support of the
- The requestor should provide data regarding physician work for the procedure
(pre-, intra- and post-time) and practice expense for both the facility and
- The requestor must provide the listed catalogue cost for any devices and
supplies involved in performing the procedure.
- The requestor must provide the names of three physicians the company feels
can comfortably analyze the procedure/device and who have no financial ties or
involvement with research, venture capital or hedge fund advisory relationship
with the company.
- Industry may forward a request to make presentations to representatives of
ACG, AGA, and ASGE. Depending on the nature of the request, a teleconference or
meeting with the representatives, at the requestor’s expense, may be scheduled.
You may contact any one of the society liaisons below to initiate
For technology/devices that are in the early stages of development, items 4
and 6 may not be applicable.
Contact Society Liaisons To Initiate Discussions
- Jennifer A. Conte, CGCS, senior director of clinical practice and
reimbursement issues, American Gastroenterological Association (AGA),
- Brad Conway, vice president, public policy, American College of
Gastroenterology (ACG), 301-263-9000, firstname.lastname@example.org.
- Denise Garris, ASGE CPT Consultant, The Korris Group, (202) 527-1069, email@example.com.
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