On December 2, 2021, Aimed Alliance submitted a comment to the Centers for Medicare and Medicaid Services (CMS) urging them to create a HCPCS code for prescription digital therapeutics (PDTs) to expand patient access to these therapeutics. Our comment recognized that while some medical devices may qualify to use HCPCS Level 1 codes, also known as Current Procedural Terminology (CPT) codes, PDTs that are software-only need a HCPCS Level 2 code for several reasons. Our comment explained that when a provider bills using a CPT code, the PDT must be provided to the patient in the provider’s office. Thus, a HCPCS Level 2 code is more appropriate for software-only PDTs which are delivered via a specialty pharmacy. Our comment can be read here.
Additionally, in conjunction with our comment to CMS Aimed Alliance also released a fact sheet on CPT and HCPCS Level 2 codes. The fact sheet explains the difference between CPT codes and HCPCS Level 2 codes and the need for CMS to create a billing pathway for PDTs to ensure that administrative barriers do not impair patient access to these therapeutics. The fact sheet can be found here.