September 25, 2007 - ASM Comments on Publication of Medically Unlikely Edits (MUEs)

Niles R. Rosen, M.D.
Medical Director, Medically Unlikely Edits
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 respond to your request for our perspective on the public release of Medically Unlikely Edits (MUEs). The ASM is the largest educational, professional, and scientific society dedicated to the advancement of the microbiological sciences, and their application to 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.

The ASM would like to offer the following comments in support of making MUEs publicly available on a quarterly basis in concert with the release of other National Correct Coding Initiative (NCCI) edits:
  1. The issue of “secret/black box edit systems” was discussed in detail during meetings of the Negotiated Rulemaking Committee on Clinical Laboratory Diagnostic Tests during 1998-2000. At that time, the consensus of the members was that all edits applied to Medicare claims payment should be publicly available. National Correct Coding edits, including MUEs are no exception to this generalization.
  1. The concern that publication of the MUE frequency edits will “game the system” is unjustified. Rather, publication of all correct coding edits provides an important source of correct coding and utilization guidance for clinical laboratories.
  1. To force laboratories to identify such edits in retrospect through denial analysis will still identify those CPT codes to which such edits are applied. In the interest of open and direct communication, it seems reasonable to delineate these edits as they are implemented to allow rapid feedback on appropriateness by all laboratory providers, not limited to those select organizations given an opportunity to comment pre-implementation.

Again, thank you for the opportunity to comment. Should additional information be required, please feel to contact us.


Vickie S. Baselski, Ph.D., Chair
Committee on Professional Affairs
Public and Scientific Affairs Board