Summary – The following Medicare Administrative Contractors (MAC) aka Carriers, have issued a proposed multi-jurisdictional Local Coverage Decision (LCD) for Multiplex Nucleic Acid Amplification Test (NAAT) PANELS FOR INFECTIOUS DISEASE Testing, Wisconsin Physician Services Insurance Corporation, CGS Administrators, LLC., Noridian Healthcare Services, LLC., and Palmetto GBA.

Medicare Jurisdiction Map.

Each has also issued an associated Local Coverage Article (LCA) with coding instructions and limitations on coverage.  Each of these states participate in the MolDX program administered by Palmetto GBA.  The coverage change takes effect April 17, 2022 in all states within each jurisdiction. 

Each laboratory within these jurisdictions will need to apply for a Z code through the MolDX program.  Each office will have to apply for a unique Z code for each panel of tests that are being ordered/performed.  (ie. if a Urology group has three separate test panels for UTI each test panel will require a separate Z code application.  For those groups using a reference lab for panels will need to apply for a Z code and the reference lab will need to apply and request sharing.  If a group has multiple lab locations and each lab is performing the same test only one application is required for the entity to which the CLIAs are assigned. 

Once the application is submitted, MolDX will perform a Technical Assessment prior to issuing the Z code.  After the TA is completed and the Z code is issued the lab will receive notification, Z code and Billing instructions.  Billing for a panel test is usually cross walked to a CPT type code and not reported with the Z code issued. 

The following link will provide additional information on the process. 


It should be noted within the LCAs for each of the MACs there is a reference either in the article that becomes effective 4/17/2022 or in the comments in response to requests from those within the MAC, that there are no FDA approved UTI panels.    Billing for UTI NAAT (PCR) tests will not be allowed until the TA is complete and the Z code is issued.  Nor will the system allow for retroactive billing of these tests. 

Additional information –

As the LCD issued covered multiple jurisdictions and virtually all states were included in the meetings for this policy, it is reasonable to assume that the other MACs will follow the intention of the LCD soon.  The remaining MACs; First Coast Service Options, NGS and Novitas do not yet participate in the MolDX program and Z codes may not be required.  However, these MACs can implement LCDs like the LCDs issued by the participating carriers.  Instead of Z codes for these states panel tests will likely be reported under PLA CPT codes.  PLA codes can be obtained from CPT and are alpha numeric, the process of obtaining a PLA code is not as time consuming as standard CPT code applications.  PLA codes are issued quarterly by the AMA.  



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Mark N. Painter is a managing Partner of PRS Consulting, LLC, the CEO of PRS, LLC and the Vice President of Coding and Reimbursement Information for Physician Reimbursement Systems, Inc. (PRS). Since co-founding PRS in 1989, Mr. Painter has served as the primary coding resource for the PRS products including Hotlines, Coding Manuals and quick reference tools, the Internet based application codingtoday.com and seminars. He has lectured to a variety of groups concerned with health care reimbursement. Mr. Painter's extensive knowledge of physician reimbursement issues has allowed him to assist insurance companies, physicians and their staff members, legal counsel, actuaries, Specialty Societies and consultants on a daily basis. He has serves has an expert to legal counsel, bio device companies and pharmaceuticals. He was a co-chair of the Colorado Clean Claims Task Force, a committee of nationally known industry experts charged with the development of single payment edit database for the state. Mr. Painter is a CPMA. Mr. Painter received his B.A. from Grinnell College at Grinnell, Iowa.