Great post IMO.
It seems reasonable to go with a fresh application due to the timeframes for submission.
Reconsideration: Would need to be submitted 30 MayNew application: Would need to be submitted 11 June
Both would be considered at the September meeting, so why not take the extra time allowed by submitting a new application to shore it up. They now have actionable feedback which you would think would put them on a path to approval.
The 5 general criteria are below. I'm not too concerned about that fact they failed two on first attempt. It's a new technology, so their application could be more scrutinised than usual as this will kind of 'set a precedent' for future codes.
Unique and Well-Defined Descriptor
The code must have a clear, concise, and unambiguous descriptor that distinguishes it from all other CPT codes.
It must represent a distinct procedure, service, or technology.
Consistency with CPT Editorial Standards
The structure, style, and terminology used in the descriptor and its guidelines must align with the current CPT Editorial Panel standards.
Non-Fragmentation of Existing Services
The proposed code must not fragment an existing service already reported under a current CPT code.
It must not duplicate existing codes, unless there is a valid reason (e.g., novel method or context).
Accurate Reflection of How the Procedure is Typically Performed
The descriptor should reflect the procedure or service as it is routinely delivered in clinical practice.
It should include any bundled or typically co-performed elements.
Not for Extraordinary Circumstances
The code cannot be proposed solely to represent rare or unusual scenarios.
The service must have demonstrable clinical utility beyond one-off or exceptional uses.
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