AUA Coding and Reimbursement Committee (CRC) Policy for Industry Interactions and CPT Code Change Application Advice/Submissions

Occasionally individuals or companies will reach out to the AUA CRC for coding guidance. In addition, medical device manufacturers or industry representatives may request coding advice from the CRC, or ask the CRC for advice or support for submission of a Code Change Application (CCA) to the American Medical Association (AMA) Current Procedural Terminology (CPT) Editorial Panel. The CRC adheres to the AMA CPT Editorial Panel criteria when considering a new CPT code or the revision of an existing CPT code. Please visit the AMA CPT webpage for more information about applying for CPT codes and the CPT Editorial Panel criteria.

The AUA adheres to strict confidentiality when considering requests for coding guidance and help or advice with the submission of a CCA. CRC members are required to disclose any conflicts of interest. If a conflict exists, that member will be recused from discussing or voting on that issue.

Steps to request coding guidance from the AUA CRC:

• Step 1 – Complete the Coding Guidance Request form for coding advice (https://www.auanet.org/leadership-and-business/institute-for-leadership-and-business/practice-management-and-coding/coding-and-reimbursement-committee/coding-guidance-request-form) to determine the correct coding for a procedure, treatment, service or device, or to ask for guidance with a new procedure, treatment, service or device. Attach any information such as marketing materials, videos and data with the request.
• Step 2 – CRC leadership will review information submitted to determine whether an established code is available or if a new Category I or Category III CPT code is necessary.
• Step 3 – If an existing Category I or Category III CPT code is available, the requestor will be notified of the appropriate CPT code to report, and the CRC will provide details for appropriate use of the code (such as limitations, modifiers needed if necessary, exclusions, bundling, etc.). No further action is required. If there is not an existing Category I or Category III CPT code available, the requestor will be notified as such.
• Step 4 – If a new or revised CPT Category I or Category III CPT code is needed, the requestor may ask for an informal meeting with CRC leadership to discuss additional steps in the CPT approval process. If the new or revised CPT code includes a device that requires FDA approval, the meeting should take place if FDA approval has already been granted or if FDA approval is pending within six months. This meeting does not establish final decisions on coding guidance but provides information on the process of the AMA CPT Editorial Panel.
• Step 5 – If FDA approval has been granted or is imminent, the requestor may be invited to the next face-to-face meeting of the CRC (typically held in spring and fall) to present information including FDA approval, marketing materials, data, and literature, and to describe why a CPT code is needed and how they believe that their device meets the CPT Editorial Panel criteria. Once the presentation has been concluded, the CRC will discuss and vote on (1) whether the criteria published by the American Medical Association CPT Editorial Panel for Category I or Category III CPT codes in place at the time of industry presentation have been met and/or (2) what feedback should be provided to the requestor concerning criteria that have not been satisfied in the CRC’s judgment. AUA staff will then notify the requestor of the CRC’s determination typically within two weeks of the CRC meeting. If additional information is necessary from the requestor, additional discussion will be tabled until the next meeting of the CRC.
• Step 6 – If the CRC deems that the requestor has met all required criteria published by the AMA CPT Editorial Panel, the AUA CRC Chair, CPT Advisor and AUA staff can assist the requestor in completing the Coding Change Application (CCA) required by the AMA.
• Step 7 – The CRC committee vote will determine the degree of assistance the AUA staff will provide the requestor in assistance with submission of the Code Change Application to the American Medical Association. The CRC will vote to: 1) oppose the CCA, 2) remain neutral (industry can present the CCA but the AUA will not comment), 3) support the CCA.
• Step 8 –If the CRC believes the technology advances science and presents compelling and extraordinary value to urology patients, the AUA will submit the CCA request for Category I or Category III CPT code to the AMA CPT Editorial Panel. View the current AMA CPT/RUC Calendar.
• Step 9 – If the CPT code is accepted by the AMA, CPT code valuation through the RUC specialty survey process for assignment or revision of RVUs for the Medicare Fee Schedule shall be conducted through the AUA, utilizing contracted services as necessary. Vendor financing of CPT code surveys, survey analysis, or preparation of information for presentation to the RUC shall not be solicited or accepted, in order to avoid the appearance or occurrence of impropriety or undue influence over the valuation process. Any effort to obtain AUA and AUA CRC approval for a request on this basis shall be rejected.

AMA CPT Lobbying Policy (https://www.ama-assn.org/practice-management/cpt/statement- lobbying) The AMA CPT Lobbying Policy must be adhered to during the entire development of a CPT code change application and especially the following:

After a code-change application is submitted to the AMA, contact between an applicant and medical society representatives should be confined to communications managed by AMA CPT staff unless the medical society is a co-requester on the code-change application.

Please note: these steps are offered as guidelines for the consideration of any request. The AUA and AUA’s CRC retain the discretion to alter these guidelines or take any actions deemed appropriate in responding to any request.

Communications between the AUA and any party relating to CPT codes are designed to help all urologists and urology patients.

For additional information or assistance, contact Bhavika Patel, Policy and Advocacy Manager for Payment and Reimbursement at BPatel@auanet.org.