Niles R. Rosen, M.D.
Medical Director
National Correct Coding Initiative
Correct Coding Solutions LLC
P.O. Box 907
Carmel, IN 46082-0907

Dear Dr. Rosen:

The American Society for Microbiology (ASM) appreciates the opportunity to review and comment on the proposed National Correct Coding Initiative Medically Unlikely Edits, Phase II. The ASM is the largest, single life sciences Society dedicated to the advancement of the microbiological sciences and their application for the common good. The Society represents approximately 42,000 microbiologists, including scientists and science administrators working in a variety of areas, including biomedical, environmental, and clinical microbiology.

Many of our members have primary involvement in clinical laboratory medicine including individuals directing clinical microbiology or immunology laboratories, individuals licensed or accredited to perform such testing, industry representatives marketing products for use, and researchers involved in developing and evaluating the performance of new technologies. Thus, our Society has a significant interest in correct coding for laboratory testing to ensure reasonable reimbursement for medically necessary laboratory testing for Medicare beneficiaries.

The ASM appreciates the need to perform systematic post-claim reviews to identify aberrant utilization patterns including over utilization or utilization that is incompatible with anatomic considerations, CPT code descriptors, CPT coding instructions, or medical standards of care. We support any reasonable program to promote correct coding and appropriate utilization. However, we still have a few concerns with this proposal as delineated in our initial comments dated 19 June 2006.

Those codes for which we disagree with the MUE assigned are attached as requested, and in general, pertain to the not uncommon practice of appropriately testing more than 1 unique sample on the same date of service by the same codeable procedure in accordance with standards of care.

The ASM appreciates the opportunity to review the Phase II proposed MUE edits and make recommendations prior to the April 1, 2007 implementation date. We support the goals of the Centers for Medicare and Medicaid Services and its contractors in the provision of medically necessary and clinically appropriate laboratory testing to Medicare Part B beneficiaries through the process of correct coding and judicious utilization. However, we are dedicated to ensuring that claims review programs not be established which could inappropriately restrict the ability of ordering providers to obtain medically necessary diagnostic information, the ability of beneficiaries to receive the benefit of quality laboratory testing, or the ability of the laboratory to receive reimbursement for such services.

Please let us know if we can provide any additional information to further assist you or to clarify our concerns and recommendations.
Vickie S. Baselski, Ph.D., Chair
Committee on Professional Affairs
Public and Scientific Affairs Board