CMS Implements Significant Updates to HCPCS Level II Coding Cycles and Procedures

The Centers for Medicare & Medicaid Services (CMS) announced that, beginning in January 2020, CMS will implement shorter and more frequent coding cycles for requests to modify the Healthcare Common Procedure Coding System (HCPCS) Level II code set. Under the updated procedures, stakeholders will be able to submit code applications on a quarterly basis for drugs and biologicals, and on a bi-annual basis for durable medical equipment, orthotics, prosthetics and supplies (DMEPOS) and other non-drug, non-biological products. CMS also will publish final coding decisions more frequently and has made additional process changes in light of the updated coding cycles. These updates represent a significant change from the prior framework that had only one submission deadline and coding cycle for each calendar year.

These updates are part of CMS’s initiative to “unleash innovation” and provide an opportunity for manufacturers and other stakeholders to benefit from more frequent opportunities to submit coding applications. According to CMS, these changes seek to improve patients’ access to new therapies and technologies. CMS forecasted these changes in May 2019, as addressed in a prior Sidley Update, emphasizing the role of these updates in “a comprehensive CMS strategy to address barriers to medical innovation in the Medicare program” and to “expedite adoption of and patient access to new medical technologies.”