Requests for changes to CPT
Specific procedures for changes to the codes and criteria for Category I and Category III codes, as well as Category II codes, exist for addressing requests to revise CPT, such as adding or deleting a code or modifying existing nomenclature.
Medical specialty societies, individual physicians, hospitals, third-party payers and other interested parties may submit applications for changes to CPT for consideration by the CPT® Editorial Panel.
The AMA’s CPT staff reviews all requests to revise CPT including applications for new and revised codes. If AMA staff determines that the Panel has already addressed the question, staff informs the requestor of the Panel's coding recommendation. However, if staff determines that the request presents a new issue or significant new information on an item that the Panel reviewed previously, the application is referred to members of the CPT Advisory Committee for evaluation and commentary.
The role of the CPT advisors
The CPT Editorial Panel meets three times each year. AMA staff prepares agenda materials for each Panel & RUC meeting. Panel members receive agenda material at least 30 days in advance of each meeting, allowing them time to review the material, review CPT advisor comments and confer with experts on each subject, as appropriate. Over a minimum of three meetings per year, the Panel addresses over 200 major topics, each reviewed and discussed with careful consideration.
A multistep process naturally means that deadlines are very important. The deadlines for submitting code change applications and for compilation of CPT advisors’ comments are based on a schedule which allows at least three months of preparation and processing time before the issue is ready for review by the CPT Editorial Panel. The initial step, which includes AMA staff and CPT advisor review, is completed when all appropriate CPT advisors have been contacted and have responded, and all information requested of an applicant has been provided to AMA staff.
Following review and compilation of CPT advisors’ comments, AMA staff prepares an agenda item that includes the application, compiled CPT advisor comments and a ballot for decision by the Panel. Once the Panel has taken an action and preliminarily approved the minutes of the meeting, AMA staff informs the applicant of the outcome.
The Panel actions on an agenda item can result in one of four outcomes:
- Addition of a new code or revision of existing nomenclature, in which case the change would appear in a forthcoming volume of CPT
- Referral to a workgroup for further study
- Postponement to a future meeting (to allow submittal of additional information in a new application)
- Rejection of the item
Applications that have not received any CPT advisor support will be presented to the Panel for discussion and possible decision unless withdrawn by the applicant. Applicants will be notified if their applications have received no CPT advisor support approximately 14 days prior to each meeting of the Panel meeting. Applicants have the ability to withdraw their applications up until the agenda item is called at the meeting—thereafter the Panel has jurisdiction over the agenda item.
Applicants or other interested parties who wish to seek reconsideration of the Panel's decision should visit the "Request for reconsideration process" page for additional information and instructions.
All complete CPT code change applications are reviewed and evaluated by the CPT staff, the CPT/HCPAC Advisory Committee and the Panel. Strict conformance with the following is required for review of a code-change application:
- Submission of a complete application, including all necessary supporting documents.
- Adherence to all posted deadlines.
- Cooperation with requests from the CPT staff and/or Panel members for clarification and information.
- Compliance with CPT Lobbying Policy, Confidentiality Agreement and Conflict of Interest Disclosure Requirements (DocuSign® electronic signature required).
Criteria for CPT codes
Before submitting changes/additions to CPT codes, make sure applications meet general and specific criteria for Category I and Category III codes, as well as Category II codes.
CPT codes implementation schedule
As the designated standard for the electronic reporting of physician and other health care professional services under the Health Insurance Portability and Accountability Act of 1996 (HIPAA), CPT codes are updated annually and effective for use on Jan. 1 of each year. The AMA prepares each annual update so that the new CPT books are available in the fall of each year preceding their effective date to allow for implementation.
Category I vaccine product codes and Category III codes are typically "early released" for reporting either Jan. 1 or July 1 of a given CPT cycle. In order to comply with HIPAA requirements, the effective dates for these codes have been altered to become effective six months subsequent to the date of release following code set updates. As a result, codes released on Jan. 1 are effective July 1, allowing six months for implementation, and codes released on July 1 are effective Jan. 1.
Molecular Pathology Tier 2 codes and Administrative MAAA codes are released three times per year (April 1, July 1, Oct. 1) following approval of the Panel minutes after each Panel meeting. The effective dates for these codes have also been altered to become effective three months subsequent to the date of release. For example, codes released April 1 are effective July 1, allowing three months for implementation.
CPT process resources
- The CPT® Editorial Panel Ad Hoc Workgroup Organizational Structure and Processes October 2011 (PDF)
- Request for reconsideration/review of CPT Editorial Panel Actions (PDF)
- Conflict of Interest Policy of the CPT® Editorial Panel (PDF)
- CPT® Confidentiality Agreement (PDF)
- Guidelines for Medical Specialty Societies Coding and Nomenclature Committee (Updated Oct. 1, 2017) (PDF)
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