PERMACODE

CPT · HCPCS · ICD-10 / ICD-10-PCS · Medicare

Approval gets you a product. Reimbursement gets you a business.

Permacode Advisors is a specialist reimbursement consulting firm. Since 2001, our practice has helped drug, biologic, and medical device teams turn approved products into paid ones: the right code, a defensible payment, and a price that holds. Every engagement is senior-led — and backed by a national network of coding, payment, payer, clinical, and regulatory experts we bring in to match the work, not a single pair of hands.

One 30-minute call. You leave with the best code path for your product, the filing clock you're actually on, and the risks most likely to get the application denied or delayed — whether we work together or not.

Since 2001Reimbursement practice
100+Applications & launches supported
$20M+/yrDenials collected — provider-side roots
National benchCMS · payer · clinical · regulatory

Project-based engagements for teams that need a firm behind the work — senior reimbursement judgment plus the specialists each filing calls for.

Every pathway. One firm.

CONTENTS — THE FULL PATHWAY INDEX

01

HCPCS Level II & J-Codes

New code applications, revisions, and MEARIS filings — the permanent code a drug, biologic, device, or supply is billed under.

02

CPT

Category I & III applications to the AMA CPT Editorial Panel — procedure and service codes payers recognize.

03

ICD-10-CM

Diagnosis code applications and Tabular / Index revisions through the ICD-10 Coordination & Maintenance Committee.

04

ICD-10-PCS

Inpatient procedure code applications, including Section X new-technology codes for procedures the set describes poorly — or not at all.

05

MS-DRG

New DRG requests and assignment reviews under IPPS — the payment group the inpatient case actually lands in.

06

New Technology APC

OPPS new-technology APC applications — device and service placement when the standard APC doesn't pay for the technology.

07

NTAP

Inpatient new technology add-on payment applications — the IPPS bridge while the cost data catch up.

08

OPPS Pass-Through

Transitional pass-through applications under §419.64 — and the packaging defense that decides what the status is worth.

09

PDAC

DMEPOS coding verification — the determinations DME MACs honor for devices, prosthetics, orthotics, and supplies.

10

PLA & Diagnostics

PLA codes and CLFS payment — plus the coverage pathway behind the code: LCD landscape, MolDx technical assessment, payer sequencing.

Ten pathways, one filing practice — and most products need more than one of them, in the right order. Not sure which are yours? That's exactly what the Code & Payment Readiness Assessment answers first.

Built for
  • Drug & biologic developers (pre-launch to marketed)
  • Medical device & diagnostics companies
  • Drug-device combinations & digital technologies
  • Office / ASC / HOPD / inpatient settings
  • Teams without a market-access VP yet

Start here

Don't start with the service list. Start with your decision.

Most teams that reach this page are facing one decision: which code, which pathway, and what could still sink the application. You don't need a market-access department to answer it — you need a firm that has sat where the denials land and filed where the codes are decided, and that can pull in the right specialists when the question runs past coding into coverage, evidence, or payment policy.

That depth is the foundation of the firm: roots in provider finance at Mayo Clinic (2001–2011), a national consultancy’s reimbursement practice (2014–2024), and launch work across pharma, biotech, and devices on roughly 50 national product launches — extended today by a vetted network of former regulators, payer-side operators, clinicians, and counsel, engaged project by project.

  • Senior-led on every engagement — the lead who scopes your work stays accountable for the analysis and the application through filing
  • Specialists matched to the project — coding, payer, clinical, regulatory, and legal expertise brought in from the firm's network where the work calls for it
  • Confidential from the first conversation; client names are never published
  • If Permacode isn't the right fit, we'll tell you on the call and point you at who is

Memorandum

TO: Launch teams facing a code decision
FROM: Permacode Advisors — Coding & Payment Practice
RE: The Code & Payment Readiness Assessment

Know your position before you file.

A fixed-scope first engagement. No retainer, no open-ended hourly meter. Five deliverables:

  • Code-path map — the code set and family most likely to stick (CPT, HCPCS, ICD-10/PCS, PDAC), and which existing codes won't work, and why
  • Filing clock — the exact cycle, panel, or committee window you're on, and what has to be true by that date
  • Risk register — the arguments most likely to draw a denial, a packaging decision, or a payment cliff, ranked by severity
  • Evidence gaps — what your trial or data plan can still capture before the window closes
  • Fixed-fee scope for the full application, if you want one — price stated before work begins
The fee model, plainly: every engagement is one fixed fee, stated in the SOW before work begins. Fees vary because each pathway's complexity differs — a J-code filing, a CPT panel application, and a PDAC verification are different undertakings. What doesn't vary: the fee in the SOW is the fee you pay.
Book your free code readiness call →

The code readiness call itself is free and lasts 30 minutes. The assessment is scoped and quoted after it — you decide with the full picture in hand.

Services — major code sets, all technologies

The work that decides whether you get paid

Fourteen engagements. Eight cover the major U.S. code sets and supplemental-payment pathways — CPT, HCPCS Level II, ICD-10-CM, and ICD-10-PCS — plus the payment classifications those codes feed: new DRG assignments under IPPS and new technology APC applications under OPPS, with independent code application reviews and general reimbursement consulting rounding out the filing practice. Six standing services sit around the filings — advisory services, investment perspective engagements, reimbursement strategy, landscape assessments, strategic assessment analysis, and the mock CMS review panel — for drugs, biologics, medical devices, diagnostics, and combination products. Each is scoped as a fixed-fee statement of work: you know the deliverable, the timeline, and the price before we start. Not sure which one is yours? That's exactly what the code readiness assessment answers first.

01

CPT Code Applications

CPT · PLA · Diagnostics

Category I, II, and III applications to the AMA CPT Editorial Panel — plus PLA codes and the coverage pathway work diagnostics actually live or die on. For devices, diagnostics, and physician-administered technologies alike.

  • Category I vs. Category III strategy and timing against FDA authorization; the Editorial Panel meets three times a year, on application deadlines set months ahead
  • Full application drafting: clinical vignettes, literature, and utilization rationale
  • RUC / valuation preparation so the code lands with a payable value
  • PLA codes for proprietary diagnostics — quarterly application and effectuation cycle, and the PLA-vs.-Category I decision: proprietary and fast, or established and broadly payable
  • CLFS payment strategy — whether CMS crosswalks your test to an existing rate or gapfills it through the MACs, and what each route does to your first years of payment
  • Coverage pathway work, in scope: LCD landscape analysis, MolDx technical-assessment support, and payer sequencing — the code gets you listed; coverage gets you paid

Best when: your technology needs a procedure or service code that payers will actually recognize — not a workaround.

02

HCPCS Level II & J-Code Applications

HCPCS · MEARIS · CMS-10224

The application CMS actually reads — built the way the HCPCS Workgroup evaluates it, precedent by precedent. Drugs and biologics file on quarterly cycles; devices, supplies, and DME file on biannual cycles.

  • Full MEARIS CMS-10224 answers (Questions A–N) with evidence binder
  • J-codes, A/E/K/Q and other Level II families; descriptor & billing-unit design with JW/JZ waste math
  • Existing-code analysis — why a miscellaneous code or a packaged supply code won’t do
  • Therapeutic / functional distinction case with systematic literature review, including unfavorable articles
  • Every draft scored in a Workgroup simulation before it files — how the simulation works

Best when: you’re 12–24 months from launch and the trial or evidence plan can still capture what the application will need.

03

ICD-10-CM & ICD-10-PCS Code Applications

ICD-10 · C&M Committee

Diagnosis and inpatient-procedure codes through the ICD-10 Coordination & Maintenance Committee (CMS + CDC/NCHS). Without the right ICD-10 code, the claim has nothing to hang on.

  • ICD-10-CM new diagnosis codes and Tabular / Index revisions
  • ICD-10-PCS new technology Section X and procedure codes for inpatient cases
  • Committee proposal drafting, presentation support, and comment-cycle strategy
  • Alignment of ICD-10 with CPT/HCPCS so inpatient and outpatient stories agree

Best when: your product treats a condition or is used in a procedure that the current code set describes poorly — or not at all.

04

New Technology Add-On & Pass-Through Applications

NTAP · OPPS · §419.64

The supplemental-payment pathways that make new technology viable while the data catch up — inpatient NTAP under IPPS and transitional pass-through under OPPS.

  • IPPS New Technology Add-on Payment (NTAP): eligibility, cost-threshold modeling, and application
  • Alternative NTAP pathway support for Breakthrough Devices and qualified technologies
  • OPPS transitional pass-through (§419.64 cost tests) and §419.2(b)(16) supply-packaging defense
  • APC-by-APC dollar hurdles and post-pass-through / post-NTAP cliff planning
  • Site-of-care strategy across physician office, ASC, HOPD, and inpatient

Best when: the base payment doesn’t cover your technology yet and you need the bridge — modeled before you promise anyone a number.

05

Medicare PDAC Applications & Coding Verification

PDAC · DMEPOS

Applications to the Medicare Pricing, Data Analysis and Coding (PDAC) contractor — the coding verification and DMEPOS determinations that decide how DME, prosthetics, orthotics, and supplies get billed.

  • PDAC Coding Verification Review applications for DMEPOS products
  • Correct Coding Initiative and product-classification strategy
  • Level II code verification letters and re-review / reconsideration support
  • Billing and documentation guidance aligned to the PDAC determination

Best when: your device or supply needs a defensible HCPCS assignment that DME MACs will honor on the first claim.

06

Pricing, Payment Analysis & Fractional Leadership

Strategy · ASP · Launch

WAC is a one-way door and payment policy moves quarterly. We run the analysis before pricing locks — and provide fractional leadership when you need it.

  • WAC / ASP trajectory modeling, ASP+6% office economics, and IRA inflation-rebate exposure
  • Commercial & Medicaid payment cross-checks by setting; UB-04 / claim-form readiness
  • Launch readiness: interim miscellaneous-code playbook before the permanent code lands
  • Payer policy monitoring, denial triage, sales-team guardrails, and quarterly steering reviews
  • Pricing checked in models built for the decision at hand — §419.64 cost tests, Question N consistency — against filings experience going back to 2001

Best when: approval is in sight and reimbursement is about to become daily weather — not an episodic project.

07

New DRG & New Technology APC Applications

DRG · APC · IPPS / OPPS

Codes get you recognized; DRGs and APCs decide what the case actually pays. We build the classification requests that place a new technology in the right payment group — inpatient MS-DRGs under IPPS and new technology APCs under OPPS.

  • New DRG applications and MS-DRG assignment requests — severity logic, CC/MCC structure, and the case-cost data CMS's annual rulemaking runs on
  • ICD-10-PCS code-to-DRG mapping analysis, so the procedure code and the payment group tell the same story
  • New technology APC applications under OPPS, including device and service category placement
  • Case-cost and charge modeling that shows whether the group actually pays for the technology
  • Post-assignment monitoring — recalibration, weight changes, and packaging exposure as the rules turn over each year

Best when: the code exists but the payment group doesn't fit — the case pays as if your technology weren't in the room.

08

Code Application Reviews & Reimbursement Consulting

Review · Second Opinion

Already have a draft — written in-house or by another firm? An independent review before you file is the cheapest insurance in this business. And for everything that isn't a filing, general consulting puts the firm's reimbursement judgment on call.

  • Independent review of CPT, HCPCS, ICD-10, DRG, APC, NTAP, and pass-through applications before filing
  • Findings ranked by severity — what a panel, workgroup, or committee will challenge, and how to fix it while there's still time
  • Second opinions on code-path, descriptor, and payment-pathway decisions already made
  • General reimbursement consulting: coding, coverage, and payment questions answered as they arise
  • Reimbursement expertise for internal teams and diligence — the risk read on someone else's coding and payment claims

Best when: the application is drafted but unfiled, or you need senior reimbursement expertise without a full application engagement.

09

Advisory Services

Advisory · Ongoing Counsel

Senior reimbursement counsel on call — the questions that don't wait for a filing cycle, answered by senior practitioners who have filed, appealed, and collected on them.

  • Ongoing senior counsel on coding, coverage, and payment questions as they arise
  • A standing second read on payer policy changes, denial patterns, and coding guidance
  • Direct access to senior advisors — no junior hand-offs, no call-center layers
  • Scoped to the hours you'll actually use, with regular steering reviews

Best when: reimbursement questions land weekly and you want one senior answer, not a research project each time.

10

Investment Perspective Engagements

Diligence · Investor Perspective

Reimbursement is where medtech and life-science valuations quietly succeed or fail. We give investors and acquirers the operator's read — before the term sheet, not after the write-down.

  • Reimbursement diligence on medtech and life-science assets: code status, coverage posture, and payment reality
  • The pathway read — what a code, NTAP, pass-through, or DRG assignment would actually require, and how long it takes
  • Revenue-model stress test: whether the forecast's coding and payment assumptions survive contact with CMS policy
  • Findings in writing, ranked by severity — the risks priced in, and the ones that aren't

Best when: you're evaluating an acquisition, an investment, or a portfolio company whose value depends on getting paid.

11

Reimbursement Strategy

Strategy · Portfolio & Launch

The plan above the filings: which codes, in which order, in which settings — set at portfolio and launch level, before individual applications are scoped.

  • Portfolio-level coding, coverage, and payment strategy across products and indications
  • Launch sequencing: code path, evidence plan, and pricing decisions ordered against the filing calendars
  • Site-of-care and channel strategy — office, ASC, HOPD, and inpatient economics compared before you commit
  • Board- and investor-ready reimbursement narratives grounded in the actual pathways

Best when: the decisions interact — multiple products, multiple settings, one launch window — and somebody has to hold the whole map.

12

Landscape Assessments

Landscape · Coding · Coverage · Payment

Before you commit to a pathway, see the whole field. A landscape assessment maps how a product or category is actually coded, covered, and paid today — the competitors, the precedents, and the gaps your strategy has to be built on.

  • Coding landscape: the codes in use across the category, who holds them, and where existing descriptors leave your product unserved
  • Coverage landscape: LCDs, payer medical policies, and MolDx postures across Medicare and commercial payers — who pays, under what conditions, and who doesn't
  • Payment landscape: rates by site of care (office, ASC, HOPD, inpatient), packaging exposure, and the supplemental pathways already in play
  • Precedent landscape: granted and denied applications in and around your category — what reviewers accepted, what they rejected, and why
  • Findings delivered as a written assessment: the map, the gaps, and the openings, ranked by what they mean for your filing and launch decisions

Best when: you're entering a category, sizing a market, or choosing a direction — and need the reimbursement terrain mapped before money is committed.

13

Strategic Assessment & Analysis

Analysis · Options · Decisions

A landscape tells you where things stand; a strategic assessment tells you what to do about it. We take the evidence — your product, the landscape, the filing calendars — and turn it into a decision: options scored, trade-offs priced, and a recommendation you can defend in the room.

  • Pathway options analysis: each viable code and payment route scored on probability, timing, payment outcome, and evidence cost
  • Scenario and sensitivity modeling — what the plan looks like if the code is granted, packaged, delayed a cycle, or denied
  • Sequencing and timing analysis against the filing calendars, FDA authorization, and launch window
  • Risk-weighted recommendation in writing — the move we would make, the alternatives considered, and the conditions that would change the call
  • Board- and investor-ready presentation of the analysis for teams that have to carry the decision upward

Best when: the options are real, the stakes are material, and the decision has to be made on analysis — not on whoever argues loudest.

14

Mock CMS Review Panel

Panel Review · Verdict · Feedback

Your application is finished — but is it ready? Before CMS sees it, a panel of former CMS reviewers drawn from the firm's expert bench reviews your completed application the way CMS will: independently, against the same criteria, and with the verdict and feedback delivered while there is still time to act on them.

  • Panel of former CMS reviewers and senior specialists from the firm's network — each reviewer works independently, so you get separate reads, not one negotiated opinion
  • A clear readiness verdict from each reviewer on the application as it stands: file it, fix it first, or rethink it
  • Field-by-field findings across the whole application — descriptor, distinction evidence, existing-code analysis, billing units, and pricing — what holds, what doesn't, and why
  • Prioritized remediation: every finding ranked by how much it moves the outcome, so the remaining window before your deadline goes to the fixes that matter
  • Findings delivered as a written panel memorandum, with a walkthrough session for your team

Best when: the application is complete and the filing deadline is close — you want CMS's likely answer before CMS gives it.

The method, on the record

How the simulation works

Every HCPCS draft is scored before it files — against the dimensions the HCPCS Workgroup actually decides on, using decision patterns from coding work going back to 2001. Not a slogan. A procedure, with an artifact you keep.

Step one — Scored

The draft is read the way the Workgroup reads it

Category first — is this a drug, a supply, or part of a procedure? Then distinction from existing products, the inadequacy of every existing code, and the integrity of the descriptor and billing units. Each dimension is graded on the precedent the Workgroup itself has set.

Step two — Reported

You receive a scored findings memo

Every weakness the simulation surfaces, ranked by severity, with the precedent behind the flag. You see the same read CMS would give the draft — before CMS does.

Step three — Fixed

The findings get fixed before filing, not after denial

Descriptor tightened, distinction evidence rebuilt, billing-unit math corrected. The application that files is the one that survived the simulation.

Workgroup SimulationScorecard
Category argumentHolds
Distinction evidenceTighten
Existing-code inadequacyHolds
Descriptor & billing unitsHolds
Pricing consistency (Q. N)Tighten

Illustrative scorecard. Your findings memo scores your draft, dimension by dimension, with the precedent behind every flag — and it is yours to keep either way.

Instrument № 2 — The Code Readiness Scorecard

Score your own code readiness

Ten questions, drawn from the same risk dimensions the Code & Payment Readiness Assessment works through: whether the code path is settled, whether the draft would hold together under review, whether the evidence is really there, and whether the filing clock still has room in it.

Answer honestly. The verdict names what to fix, in the order a reviewer would find it.

What this is not: the HCPCS Workgroup simulation. That instrument scores an actual draft against Workgroup precedent and returns a written findings memo. This is a self-check — a taste of the rigor, before there's a draft to score.

Code Readiness ScorecardSelf-scored
Code-path clarity

1. Do you know which code set and family your product belongs in — CPT, HCPCS, ICD-10, or PDAC?

Code-path clarity

2. Have you confirmed that no existing code adequately describes your product — and can you say why, in writing?

Descriptor & billing-unit integrity

3. Are the descriptor wording and billing units worked out — dose, unit math, and how waste is handled?

Category & packaging exposure

4. Could your product be read as a supply or as part of a procedure — and do you have the argument against that reading?

Evidence readiness

5. Were the endpoints or data points your application will rely on captured prospectively — in the trial, study, or data plan?

Literature readiness

6. Has the literature been reviewed systematically — including the unfavorable articles, with rebuttals?

Filing-clock fit

7. Do you know which filing deadline you are on — and what has to be true by that date?

Filing-clock fit

8. Is your FDA authorization timing clear enough to pick a filing cycle — without promising a quarter in writing?

Pricing consistency

9. Does every number agree — the price in the application, the forecast, and the story the field will tell?

Interim plan

10. Do you have a billing plan for the period before a permanent code takes effect — miscellaneous codes, setting by setting?

Where it would be challenged

    Book your free code readiness call →

    How engagements work

    Project by project. Fixed fee. No surprises.

    Most teams start with one project. Each is a standalone SOW with objective, scope, deliverables, timing, and the inputs we’ll need from you.

    Step 1 — Code readiness call

    30 minutes, real answers

    Where you are in development, what the filing clock allows, and what “paid” needs to look like.

    • No fee, no pitch deck
    • Leave with a code path, a deadline, and your top risks
    • Honest read on whether we’re the right fit

    Step 2 — Proposal

    Fixed-fee SOW

    Objective, deliverables, milestones in weeks-from-kickoff, and your inputs listed up front.

    • Day-for-day shift if your inputs slip
    • Out-of-scope named, not buried

    Step 3 — Build

    Drafts you can react to

    Early analysis first (trial-evidence needs go to your clinical team while they can still act on them), then the full package.

    • Interim briefing before the final memo
    • One legal review cycle included

    Step 4 — Harden & file

    Reviewer-ready

    HCPCS drafts are run through the Workgroup simulation and fixed against its findings. You file — we’ve made sure it’s ready to.

    • Filed at the first deadline you qualify for — quarterly or biannual (HCPCS by product type), panel (CPT), or committee / rulemaking (ICD-10, NTAP, pass-through)
    • Interim billing playbook ready before the first claim

    Instrument № 1 — The Filing Clock

    Run your own clock

    Pick your pathway and the date your application could be ready to file. The instrument works the calendars backwards — next deadline, decision window, earliest realistic effective date.

    Next deadline

    —

    Decision window

    —

    Earliest realistic effective date

    —

    Book your free code readiness call →

    Planning estimate, computed from the published filing calendars summarized below — confirmed on the code readiness call, where your product's actual evidence and authorization dates set the real clock.

    The calendars, on one line

    Field notes from live filing work

    What CMS is actually asking

    Short, specific briefings drawn from live filing work. No gated PDFs, no “thought leadership” fog.

    MEARIS · Questions A–N

    What CMS actually asks in a J-code application

    Anyone can download CMS-10224. The Workgroup isn’t grading your form — it’s grading whether you’ve answered the questions behind the questions.

    Question C (category) is where topical and supply-adjacent products die. If your product can be described as “used with a procedure,” expect the supply-packaging argument — name the adverse precedent yourself and distinguish it on labeled dose, NDA status, and demonstrated effect. Waiting for CMS to raise it means you’ve already lost the framing.

    Question G (therapeutic distinction) requires a systematic literature review including unfavorable articles with rebuttals. “No head-to-head data exists” is not an answer; a similar-products table built from labels is. And the trial is your evidence engine — if the endpoints weren’t captured prospectively, no writer can invent them later.

    Question K (FDA status) sets your real calendar: the package should be built and hardened before approval, then filed at the first quarterly deadline (11:59 p.m. ET, first business day of Jan/Apr/Jul/Oct) with the unredacted approval letter in hand. Filing-to-effective runs about six months.

    OPPS · §419.2(b)(16)

    The supply-packaging trap

    A drug CMS decides is a “supply” doesn’t get a worse code. It gets packaged — paid at $0 as a separate line, forever.

    The pattern is consistent: a product applied at the time of a procedure, without a separately identifiable labeled dose and effect, reads to the Workgroup as part of the tray. Once packaged under §419.2(b)(16) — or denied a code on that logic — there is no pass-through to rescue it, because pass-through requires a code first.

    The defense is built early: per-patient drug record kept separate from the procedure documentation, dose tied to the label, site-of-care data (office / ASC / HOPD) captured so Question M percentages come from one utilization model. The office channel matters here too — physician-office Part B (ASP+6%) has no packaging rule, which is why office-first is the commercial backbone for so many specialty launches.

    Filing calendar · Quarterly cycles

    The quarterly clock runs your launch

    The filing calendar is fixed — which cycle you file in is a launch-sequencing decision, not paperwork.

    HCPCS drug and biological applications close at 11:59 p.m. ET on the first business day of January, April, July, and October, and the application must be complete — FDA authorization documents included; non-drug HCPCS (devices, supplies, DME) follow a biannual cycle. From filing to an effective permanent code is roughly six months on the quarterly track, which means your cycle choice is a launch-sequencing decision, not paperwork.

    Two disciplines protect you: never file a placeholder price (Question N must agree with the pricing analysis, the forecast, and the field story), and never promise an “expected quarter” for FDA action in writing. Build the mock package now; let the approval letter pick the cycle.

    Diagnostics · PLA · Coverage

    The code is half the diagnostics fight

    A PLA code gets your test listed. It does not get it covered, and it does not set its price. Diagnostics launches are won or lost on what happens after the code.

    The code. PLA codes run on a quarterly application and effectuation cycle — faster than Category I, but proprietary: the code describes your test, and only your test. The PLA-vs.-Category I decision is a strategy call about how the test will be used and paid for over its life, not a formality.

    The price. Under the Clinical Laboratory Fee Schedule, CMS either crosswalks a new test to an existing rate or gapfills it through the MACs. Crosswalk to the wrong comparator and the rate is set before you've argued anything; gapfill means a year of contractor pricing before a national rate settles. Either way, the argument is made at application time, not after.

    The coverage. For molecular diagnostics, Medicare coverage runs through LCDs and, in MolDx jurisdictions, a technical assessment of the evidence. Sequencing matters: the Medicare coverage path first, then commercial payer policies built on it. A diagnostics engagement here includes that pathway work — LCD landscape, technical-assessment support, payer sequencing — because a covered code at a real rate is the deliverable; a code alone is a listing.

    For the file — and the board memo

    Permacode at a glance

    The whole practice on one page. Print it; it is designed to be carried into the meeting.

    EngagementWhat you getTypical clockFee
    Code Readiness AssessmentCode-path map, filing clock, risk register ranked by severity, evidence gaps, fixed-fee scope for the full applicationOne fixed-scope engagement, scoped on the code readiness callFixed fee in SOW
    CPT / PLA applicationsFull application and valuation preparation; PLA strategy, CLFS crosswalk/gapfill analysis, coverage pathway workEditorial Panel cycle; PLA quarterlyFixed fee in SOW
    HCPCS / J-codeComplete CMS-10224 (Questions A–N) package with evidence binder, scored in the Workgroup simulation before filingQuarterly filing; roughly six months filing-to-effectiveFixed fee in SOW
    ICD-10-CM / PCSCommittee proposal, presentation support, comment-cycle strategyC&M Committee cycle; effective Oct 1 (PCS also Apr 1)Fixed fee in SOW
    NTAP / pass-throughEligibility analysis, cost-threshold and §419.64 modeling, application, post-program cliff planAnnual IPPS / OPPS rulemaking clocksFixed fee in SOW
    New DRG / new tech APCClassification request with case-cost and charge modeling; code-to-group mapping analysisAnnual rulemaking cycleFixed fee in SOW
    Medicare PDACCoding Verification Review application and billing guidance aligned to the determinationContractor review cycleFixed fee in SOW
    Application reviewIndependent pre-filing review; findings ranked by severity, with fixes, while there is still timeSet in the SOW around your filing deadlineFixed fee in SOW
    Pricing / fractionalWAC/ASP and payment analysis, launch playbook, payer monitoring, quarterly steeringOngoing, on a quarterly rhythmFixed fee in SOW
    Advisory servicesOngoing senior counsel on coding, coverage, and payment questions from the firm's senior advisors and network specialistsOngoing, scoped to the hours you'll useFixed fee in SOW
    Investment perspectiveReimbursement diligence and perspective for investors and acquirers evaluating medtech and life-science assetsSet against the deal timelineFixed fee in SOW
    Reimbursement strategyPortfolio- and launch-level coding, coverage, and payment strategy — the plan above the filingsSet in the SOW around your launch windowFixed fee in SOW
    Landscape assessmentWritten map of the coding, coverage, payment, and precedent landscape for your product or category — gaps and openings rankedSet in the SOW; typically ahead of a filing or investment decisionFixed fee in SOW
    Strategic assessment & analysisPathway options scored, scenarios modeled, and a risk-weighted written recommendation — board- and investor-readySet in the SOW around your decision dateFixed fee in SOW
    Mock CMS review panelYour completed application reviewed independently by a panel of former CMS reviewers — readiness verdicts, field-by-field findings, and remediation ranked by impactSet in the SOW ahead of your filing deadlineFixed fee in SOW

    On fees: no two pathways carry the same complexity, so no honest price list exists — every engagement is one fixed fee, stated in the SOW before work begins, typically 50% on execution and 50% on delivery. On references: client names are never published; references are available under NDA after the code readiness assessment.

    About

    A specialist firm with a deep bench.

    The firm’s track record — and the network behind it

    Coding & payment applications and product launches supported

    Extensive, and still ongoing. This is the firm’s collective record in reimbursement, since 2001 — accumulated application by application, launch by launch, and extended on every project by the specialists our network brings with it.

    Since 2001Reimbursement — ongoing
    $20M+/yrDenials collected — team of seven led
    $55MAnnual revenue impact

    You are hiring a firm, not a capability deck. Coding and payment applications sit at the intersection of coding policy, clinical evidence, and pricing — too specialized for market-access generalists, too episodic for most drug and device companies to staff. Permacode has done this work since 2001 — from inside a major academic medical center's finance operation, from a national consultancy's reimbursement practice, and as the firm launch teams call when the code decision is on the line.

    That range matters to how your application gets built — and no single résumé covers all of it. Practitioners who have collected on denials know which descriptor wording a payer will hide behind. Specialists who have supported ~50 national launches know which evidence a committee will ask for before your trial locks. Analysts who have run the pricing math know when a number in the application contradicts the forecast. Permacode assembles that range for each engagement: a senior lead accountable start to finish, the right network experts behind the work, and every project scoped as a fixed-fee engagement with named deliverables.

    Client names stay confidential. The record below is the firm's, and it's verifiable.

    Credentials & diligence

    MHA — Des Moines University, 2011
    Master of Health Care Administration. Verifiable with the university.
    CPC — AAPC
    Certified Professional Coder. Credential verifiable with the AAPC.
    At engagement
    Full legal identity, business registration, and professional-liability (E&O) details are provided with the statement of work — diligence gets its answers at the moment a real engagement is on the table.
    References
    Available under NDA after the code readiness assessment.

    The network behind the firm

    A senior lead accountable on every engagement — and behind that lead, a broad bench of industry-leading experts Permacode engages and matches to the work. Whatever expertise a reimbursement question needs, it is on call: former CMS and regulatory officials, payer-side operators, clinicians, coding and payment specialists, industry builders, and counsel — assembled per project, so the team in the room is the team the filing actually requires.

    • CMS
    • Mayo Clinic
    • Regulatory affairs
    • Payer operations
    • Clinical & evidence
    • Pricing & market access
    • Consulting
    • Medtech
    • Legal

    2001–2011 · Provider finance

    Where the denials land — learned from inside Designed a chemotherapy reimbursement program. Led a seven-person denials-appeals team collecting $20M+ per year; work contributed to $55M in annual revenue impact. Individual Award for Excellence (2009).

    2011–2013 · Oncology reimbursement

    Provider-side recovery Recovered $1.3M+ in aged claim denials within one year across multi-site oncology and infusion centers — the operational view of what happens when coding and payment decisions meet real claims.

    2014–2024 · Director of Reimbursement

    National market-access consultancy (acquired by Fingerpaint) Coding, reimbursement, and market access for specialty pharma and Fortune 500 clients; served as the government-payer expert resource for an expert team of roughly 15.

    Since 2011 · Independent consultant

    Roughly 50 national product launches Reimbursement expert across pharma, biotech, and medical devices — coding spanning HCPCS, CPT, ICD-10, APC, DRG, and NTAP; supported Medicare NTAP applications and new code applications; payer messaging, coverage pathways, and field training.

    Commitment

    No guaranteed outcomes — ever Coding and payment decisions belong to CMS, the AMA, and the committees. Our commitment is a package ready for their best scrutiny — and an honest read when the evidence isn't there yet.

    Common questions

    Before you ask

    Answers, not a pitch. In 30 minutes you'll get: the code path we'd pursue for your product (and which existing codes won't work, and why), the filing cycle or committee window you're actually on, and the risks most likely to draw a denial, a packaging decision, or a payment cliff. If a fixed-fee code readiness assessment or full application makes sense, we'll scope it after the call. If your evidence isn't ready or we're not the right fit, we'll tell you that too.

    Earlier than feels natural. The strongest driver of any code application — your clinical and distinction evidence — comes from the trial, pivotal study, or evidence plan, and endpoints can only be captured prospectively. Starting 12–24 months before expected authorization lets the protocol do double duty. The mock package can be completed and stress-tested before approval; the FDA letter then gates the filing, not the work. The same discipline applies to NTAP and pass-through, which are filed on CMS’s annual / quarterly rulemaking clocks.

    For HCPCS drug/biological filings, roughly six months from a complete quarterly filing (first business day of January, April, July, October, 11:59 p.m. ET); non-drug HCPCS (devices, supplies, DME) file biannually with longer lead times. CPT runs on the AMA Editorial Panel’s meeting cycle — PLA codes quarterly — and ICD-10 on the Coordination & Maintenance Committee’s spring/fall cycle with October 1 (and April 1 for PCS) effectuation — so the calendar differs by code set, but the rule doesn’t: your interim billing playbook needs to be ready before the first claim, not after the code lands.

    No — and be wary of anyone who does. Those decisions belong to CMS, the AMA, and the Coordination & Maintenance Committee. What we guarantee is the quality of the package: arguments informed by coding decisions going back to 2001, evidence assembled the way reviewers require it, and — for HCPCS work — a simulation-based stress test before you file. Every SOW we sign carries that regulatory-outcomes term in writing.

    One fixed fee per project, stated in the SOW before work begins — typically 50% on execution, 50% on delivery of the final package. Fees are not published because they genuinely vary: each pathway's complexity differs, and a fee quoted without knowing your product, your evidence, and your deadline would be a guess dressed as a number. What is fixed is the model — most engagements start with the Code & Payment Readiness Assessment, so you know the code path, the filing clock, and the exact fee for the full application before committing to it. The Workgroup simulation (for HCPCS work) and the pricing models are built into that fee — no separate reviewer pass-through or per-tool charge. Work beyond scope is only ever at a stated hourly rate with your prior written approval. No blended hourly meters.

    Engagements here are project-based — that's the model, and nothing converts automatically. If, after launch, you want ongoing support — payer policy changes, denial patterns, coding questions as they arise — a retainer is available when a client asks for one, scoped to the hours you'll actually use, with quarterly reviews and termination protection on both sides. It exists because clients request it, not because the first project funnels you into it.

    Two tools, named for the work they actually do. For HCPCS filings, the draft goes through a Workgroup simulation: it is scored on the dimensions the HCPCS Workgroup decides on — category, distinction, existing-code inadequacy, descriptor and billing-unit integrity — using decision patterns from coding work going back to 2001. You receive a scored findings memo, and the weak points are fixed before filing; the procedure is laid out here. For pricing, models built for the decision at hand check that every number in the package agrees — including §419.64 cost tests and Question N consistency. No other pathway is "simulated," and nothing about the tools is a black box: you see the findings, in writing.

    Contact

    Request your code readiness call

    Tell us what you're trying to secure and where you are: product type (drug, device, diagnostic, or combination), expected authorization window, the code or pathway you need, and the channel you're counting on. You'll get the code path we'd pursue, your filing deadline, and your top risks on the call. We reply — usually within one business day.

    Permacode Advisors

    Working with launch teams nationally. Calls by appointment — or just call.

    BasedServing clients nationally
    ModelFixed-fee projects · CPT / HCPCS / ICD-10 · Drugs & devices · Applications grounded in practice since 2001

    Request a code readiness call

    30 minutes, no fee. You leave with a code path, a filing deadline, and your top risks.

    Book your free code readiness call →

    Books straight onto the calendar — pick the time that suits you. Prefer to talk first? Call (507) 358-5381.

    Prefer to write first? Send the intake instead:

    Your request is ready.

    Here is exactly what will be sent. One click opens it in your email app, addressed to [email protected] — review it, press send, and it reaches the Permacode team. We reply usually within one business day.

    Send the request →

    No email app handy? Write to [email protected] directly, or call (507) 358-5381. Edit the request

    Prefer to talk first? Call (507) 358-5381, or email [email protected] directly. Client identities and product details are treated as confidential from the first conversation.

    The code decision happens once. Get it right the first time.

    A 30-minute call costs nothing — and you leave with the code path, the filing clock, and your top risks.

    Book your free code readiness call →