Statement on Lobbying
Applicants and other interested parties must not engage in “lobbying” for or against code change requests. “Lobbying” means unsolicited communications of any kind made at any time (including during Editorial Panel meetings) for the purpose of attempting to improperly influence either:
- CPT/HCPAC Advisors or their societies’ evaluation of or comments upon a code change request or
- Voting by members of the Editorial Panel on a code change request
Any communication that can reasonably be interpreted as coercion, intimidation or harassment is strictly prohibited. Violation of the prohibition on lobbying may result in sanctions, such as being suspended or barred from further participation in the CPT process.
Information that accompanies a code change request, presentation or commentary to the Editorial Panel during an open meeting or to a workgroup during a workgroup meeting, and responses to inquiries from a Panel member or a CPT staff member, do not constitute “lobbying.”
In order for the CPT Editorial Panel to effectively review and act on proposed changes to the CPT code set, code change applications must be reviewed by CPT/HCPAC Advisors and the Editorial Panel based on the information contained in the application and available clinical literature. CPT staff is responsible for organizing and submitting information to CPT/HCPAC Advisors and the Editorial Panel for consideration. Information relating to a code change application must be submitted to CPT staff no later than 30 days prior to the start of the Editorial Panel meeting at which the code change application will be considered. In some cases, the Chair of the Editorial Panel may establish rules which allow for supplemental submissions of information to workgroups or facilitation sessions established by the Chair or for postponed or appealed agenda items. (A “facilitation session” is an informal meeting requested by the Chair during a CPT Editorial Panel meeting to allow interested parties to confer and attempt to reach a consensus recommendation for presentation at the meeting.)
During development of a code-change application, an applicant may seek input or assistance from a medical specialty society but may not engage, either directly or via proxies, in “lobbying” as defined above. Requests for input or assistance should be directed to the society’s staff or leadership as indicated in the society’s guidelines. Such requests may not be made after the deadline for submission of applications for an upcoming meeting of the CPT Editorial Panel. Application deadlines are posted on the Calendar for Upcoming Meetings of the CPT® Editorial Panel page.
Medical specialty societies may have their own policies governing interactions with applicants or other interested parties regarding code change requests. The AMA encourages medical societies to work with applicants, from both industry and other medical specialty societies, to assure that code change applications are complete, coherent and consistent with current medical practice and does not discourage specialty society advisors from seeking advice or clarification of information from Panel members on new agenda items or items of old business through the process managed by AMA staff. Contacts with consulting medical societies should be limited to that which is necessary to construct and submit the code change application. After a code change application is submitted to the AMA, contact between an applicant and medical society representatives should be confined to communications managed by the AMA CPT staff unless the medical society is a co-requester on the code change application.
If an entity that does not have a CPT/HCPAC Advisor learns of an application to which it may be an “interested party,” the entity may request an opportunity to review the code change application and submit a written comment to the AMA for consideration by CPT/HCPAC Advisors and the CPT Editorial Panel. The entity must deliver such a request to AMA CPT staff and not contact the applicant or CPT/HCPAC Advisors or members of the CPT Editorial Panel. If an applicant or other interested party wishes the CPT/HCPAC Advisors or the Editorial Panel to consider additional information, that information must be submitted to AMA's CPT staff and not directly to CPT/HCPAC Advisors or the Editorial Panel.
Applicants and other interested parties are invited to participate in open CPT Editorial Panel meetings and present their views on code change requests when recognized by the Chair during the course of the meeting. The views of applicants and other interested parties may be sought during work group or facilitation sessions established by the Chair, and participation in a workgroup or a facilitation session is not considered lobbying.
Complaints about lobbying should be reported promptly in writing to the Director, CPT Coding and Regulatory Affairs.
Criteria for Development and Evaluation of CPT Category I and Category III Codes
Application Submission Requirements
All CPT code change applications are reviewed and evaluated by CPT staff, the CPT/HCPAC Advisory Committee, and the CPT Editorial 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 CPT staff and/or Editorial Panel members for clarification and information
- Compliance with CPT Lobbying Policy
General Criteria for Category I and Category III Codes
All Category I or Category III code change applications must satisfy each of the following criteria:
- The proposed descriptor is unique, well-defined, and describes a procedure or service which is clearly identified and distinguished from existing procedures and services already in CPT.
- The descriptor structure, guidelines and instructions are consistent with current Editorial Panel standards for maintenance of the code set.
- The proposed descriptor for the procedure or service is neither a fragmentation of an existing procedure or service nor currently reportable as a complete service by 1 or more existing codes (with the exclusion of unlisted codes). However, procedures and services frequently performed together may require new or revised codes.
- The structure and content of the proposed code descriptor accurately reflects the procedure or service as typically performed. If always or frequently performed with 1 or more other procedures or services, the descriptor structure and content will reflect the typical combination or complete procedure or service.
- The descriptor for the procedure or service is not proposed as a means to report extraordinary circumstances related to the performance of a procedure or service already described in the CPT code set.
- The procedure or service satisfies the category-specific criteria set forth below.
A. Category I Criteria
A proposal for a new or revised Category I code must satisfy all of the following criteria:
- All devices and drugs necessary for performance of the procedure or service have received FDA clearance or approval when such is required for performance of the procedure or service.
- The procedure or service is performed by many physicians or other qualified health care professionals across the United States.
- The procedure or service is performed with frequency consistent with the intended clinical use (i.e., a service for a common condition should have high volume, whereas a service commonly performed for a rare condition may have low volume).
- The procedure or service is consistent with current medical practice.
- The clinical efficacy of the procedure or service is documented in literature that meets the requirements set forth in the CPT code change application.
B. Category III Criteria
The following criteria are used by the CPT/HCPAC Advisory Committee and the CPT Editorial Panel for evaluating Category III code applications:
- The procedure or service is currently or recently performed in humans AND
At least 1 of the following additional criteria has been met:
- The application is supported by at least 1 CPT or HCPAC advisor representing practitioners who would use this procedure or service OR
- The actual or potential clinical efficacy of the specific procedure or service is supported by peer reviewed literature which is available in English for examination by the Editorial Panel OR
- There is (a) at least 1 Institutional Review Board approved protocol of a study of the procedure or service being performed, (b) a description of a current and ongoing United States trial outlining the efficacy of the procedure or service, or (c) other evidence of evolving clinical utilization.
Frequently Asked Questions
View the Frequently Asked Questions regarding the CPT Process.
CPT Process Information and Documents
CPT Code Application Form Instructions
AMA CPT Instructions for submitting a code application.
Category I and Category III Code Application
AMA CPT Application for a Category I or Category III code.
Form updated Feb. 18, 2016
Category I "Short Form" Code Application (DOC)
AMA CPT Code Application for use by Specialty Societies only. Use this form when submitting an application that is required by the Relativity Assessment Workgroup.
Form updated Oct. 15, 2015
CPT Pathology & Laboratory Code Application
AMA CPT Code Application for Pathology and Laboratory codes.
Form updated Feb. 16, 2015
Category II Code Application
AMA CPT Category II Code application and instructions.
CPT Sample Format for Required Clinical Vignette(s)
AMA CPT Sample clinical vignette for CPT process.