Six Timepoints, Then Nothing After Year Five

If you bill transplant rejection testing, the policy you have worked against since 2021 stops existing on Saturday.

Four Local Coverage Determinations titled MolDX: Molecular Testing for Solid Organ Allograft Rejection retire on August 29: Palmetto GBA, both Noridian jurisdictions, and WPS. Their four companion billing and coding articles retire the same day.

Five replacements take effect August 30, with CGS joining the set. They have been on notice since July 16, a 44-day clock that ends this weekend.

The coverage criteria section went from 586 words to 1,056. The number that matters most to a kidney program is not in the LCD at all.

"What did forty-four comment letters actually buy?"

What the Comment Campaign Bought

The draft capped first-year surveillance testing at Kidney (4), Heart (12), and Lung (12), then cut it to 2 per year after that. It called those a maximum.

The final says the service "may include" Kidney (6), Heart (12), Lung (12) in year one, and 4 per year in years 2 and 3 (chart below).

So kidney year one went up 50% and the post-year-one allowance doubled. Heart and lung year one did not move a single timepoint.

Across a recipient's first three years, the covered count goes from 4 + 2 + 2 = 8 to 6 + 4 + 4 = 14. A 75% increase, in two edits.

That is what the record bought, and the record is worth looking at. The Response to Comments article carries 44 comment and response pairs: ISHLT, the American College of Cardiology, AST, ASTS, the College of American Pathologists, ACLA, the Coalition for 21st Century Medicine, the American Kidney Fund, transplant physicians writing under their own names, and CareDx, Natera, Verici Dx and Eurofins.

43 of the 44 responses say some version of "Please see Response #1."