Ann: Response to ASX Price Query, page-48

Who is this absolute ramper of a poster @8258857 hahah holy hell. Sir, your posts are not even slightly related to reality. No facts or legit info. It's almost like you're working for the company.

@Tristan576 - great work on your post, 10:04am Monday morning, is BEFORE EIQ would have been trading. If you did sell out in the $0.30s - congrats. Absolutely stella trade.

I got out long ago - sad I didn't get the ride up, this situation is an eyebrow raiser, that's for sure.

I think posters and investors really need to re-read the AMA information, and some of the corresponding information

https://www.ama-assn.org/system/files/may-2025-summary-of-panel-actions.pdf

The document was last updated on 16 May 2025.

The schedule is well publicised, and the timing of panel meetings and the summary of panel being released is very consistent https://www.ama-assn.org/about/cpt-editorial-panel/cpt-editorial-panel-meeting-process-calendar

A public company cannot reasonably claim that a price-sensitive regulatory decision wasn’t picked up because a single executive was sick and hadn’t checked his emails. That’s not a governance failure — it’s a governance collapse.

1. Companies applying for CPT codes know exactly when the CPT Summary of Actions is published (e.g. 16 May 2025 this cycle).
2. The AMA explicitly informs the applicant (EIQ) of the outcome at or near the same time as public release.
3. Not having any compliance or regulatory process to monitor this — especially after submitting a CPT application — is deeply negligent.

The timing makes the "response" (excuses) implausible

1. The AMA’s Summary of Panel Actions was publicly released on Friday, 16 May 2025.
2. The rejection letter was emailed Saturday morning (1:00am AEST, 17 May).
3. Trading opened Monday morning, and only midday Monday did they act.
4. That’s >2 full days (including Monday morning trading) during which they could and should have known.

No Explanation of Controls or Redundancies

1. There is no mention of any backup regulatory process, escalation protocol, or coverage arrangement for key personnel.
2. This is unacceptable for a company engaging with high-stakes U.S. reimbursement processes.

No Clarification of Market Misperceptions

1. The company previously implied it was nearing commercialization (including via investor marketing).
2. The rejection undermines that narrative, yet there is no apology, clarification, or shareholder-oriented language in this response — only process excuses.

General Criteria for CPT Code Applications

According to the AMA, all code change applications must satisfy the following general criteria:

1. Unique and Well-Defined Descriptor: The proposed code must have a descriptor that is unique, well-defined, and clearly distinguishes the procedure or service from existing codes.
2. Consistency with CPT Standards: The descriptor's structure, guidelines, and instructions should align with current CPT Editorial Panel standards for maintaining the code set.
3. Non-Fragmentation: The proposed code should not represent a fragmentation of an existing procedure or service, nor should it be currently reportable as a complete service by one or more existing codes (excluding unlisted codes).
4. Accurate Reflection of Typical Performance: The code descriptor should accurately reflect the procedure or service as typically performed. If the procedure is commonly performed with other services, the descriptor should represent the typical combination.
5. Not for Extraordinary Circumstances: The code should not be proposed solely to report extraordinary circumstances related to a procedure or service already described in the CPT code set.

Why Failing General Criteria Is Serious

These 5 general criteria are the baseline prerequisites for any CPT code — even a temporary, non-reimbursed Category III code. These aren’t just technicalities. They ensure that:

1. The procedure is real, not conceptual
2. It’s used in practice, not just in pilot studies
3. It’s clearly defined and can be consistently reported
4. It’s not duplicative of existing services
5. It’s suitable for tracking, i.e., has some plausible clinical utility

To me, failing two out of five general criteria is exceptionally significant.

If it was a 'simple fix' then 'reconsideration' is the appropriate course of action

https://www.ama-assn.org/about/cpt-editorial-panel/summary-panel-actions

https://www.ama-assn.org/system/files/cpt-panel-action-reconsideration.pdf

AMA Reconsideration Process (as of 16 May 2025)

1. A reconsideration request can reverse or modify a Panel decision if either of the following standards is met:
2. Prong (i): Material Existing Information Was MissingInformation existed at the time of the original reviewIt was not presented to the PanelIt was relevant to the code application
3. Prong (ii): Procedural ErrorA procedural irregularity occurred that likely affected the outcome
4. Important: New information developed after the submission deadline cannot support reconsideration — in that case, a new application is required.

Timing of Reconsideration

1. Reconsideration requests must be submitted within 14 days of the Summary of Panel Actions being published.
2. For the May 2025 meeting (released 16 May 2025), the deadline is 30 May 2025.

EIQ’s Claim vs Reconsideration Path - EIQ says:

1. The rejection was based on two general criteria not being met
2. They believe they can revise the application to address those issues
3. But they didn’t request reconsideration — they are submitting a fresh application

If the issues were just a matter of better framing or emphasizing evidence that already existed, they could have gone the reconsideration route — which:

1. Would nullify the rejection
2. Keep the current application “alive”
3. Get reconsidered at the next CPT Panel meeting (September 2025) — same as a new submission would

So unless:

1. The new material EIQ wants to submit didn’t exist before the original deadline, or
2. The deficiencies were fundamental and fatal

... then their failure to request reconsideration is telling.

It will be interesting to see what further information is released by EIQ, especially regarding the two general criteria that were not met.