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Routine Costs Associated with Qualifying Clinical Trials
07.00.20g

Policy

State mandates do not automatically apply to self-funded groups; therefore, individual group benefits must be verified.

Routine costs associated with qualifying clinical trials, as defined in this policy​, are covered and eligible for reimbursement consideration by the Company.

US Food and Drug Adminstration (FDA) approved prescription pharmaceuticals and biologics are eligible for coverage and reimbursement consideration when both of the following criteria are met:
  • The prescription or biologic is not otherwise funded by the qualifying clinical trial.
  • ​The prescription or biologic is being used for an FDA approved indication and/or is used for a covered indication in medical policy.​​
NONCOVERED SERVICES

The following services associated with a qualifying clinical trial are not covered by the Company and, therefore, not eligible for reimbursement consideration:
  • Any services that the individual's plan does not routinely cover, such as, but not limited to services that:
      • Are a specified benefit exclusion
      • Have met or exceeded a benefit limitation described in the member contract
      • Are deemed not medically necessary
The following items and​ services, associated with a qualifying clinical trial are not covered by the Company because they are not considered routine. Therefore they are not eligible for reimbursement consideration:
  • T​he investigational item, device, drug or service itself. 
  • The items and services provided solely to satisfy data collection and analysis needs, which are not used in the direct clinical management of the individual enrolled in the qualifying clinical trial 
  • The items and services ​(including prescription pharmaceuticals and biologics) customarily provided free of charge by the research sponsors for any individual enrolled in the qualifying clinical trial 
  • A service that is clearly inconsistent with widely accepted and established standards of care for a particular diagnosis.
REQUIRED DOCUMENTATION

The individual's medical record must reflect the medical necessity for the care provided. These medical records may include, but are not limited to: records from the health care professional's office, hospital, nursing home, home health agencies, therapies, and test reports.

Additional documentation that may be requested to confirm that the trial meets policy requirements include:
  • The trial name, trial sponsor, ClinicalTrials.gov identifier number, and sponsor-assigned protocol number
  • The specific routine items and services provided to the individual (Time and Event schedule or approved study budget)
  • Copy of the signed and dated study-specific Informed Consent Form
  • The specific FDA-approved prescription pharmaceutical(s) or biologic(s)being used in combination with a clinical trial that are and are not supplied or paid for by the clinical trial sponsor
The Company may conduct reviews and audits of services to our members, regardless of the participation status of the provider. All documentation is to be available to the Company upon request. Failure to produce the requested information may result in a denial for the service.

BILLING REQUIREMENTS

Providers must report both of the following with each procedure code that represents a routine cost associated with a qualifying clinical trial or an FDA-approved prescription pharmaceutical or biologic:
  • Modifier Q1 (routine clinical service provided in a clinical research study that is in an approved clinical research study)
    Note: Facility providers that do not report Current Procedural Terminology (CPT®) or Healthcare Common Procedure Coding System (HCPCS) code(s) are not required to report this modifier.
  • The International Classification of Diseases, 10th Revision (ICD 10) code Z00.6 (Encounter for ​examination for normal comparison and control in clinical research program) 
Providers must report Modifier Q0 (investigational clinical service provided in a clinical research study that is in an approved clinical research study) with each procedure code that represents an investigational item, device, drug or the investigational service itself.

Inclusion of a code in this policy does not imply reimbursement. Eligibility, benefits, limitations, exclusions, precertification/referral requirements, provider contracts, and Company policies apply.

Guidelines

MANDATES

This policy is consistent with applicable Federal and state mandates. The laws of the state where the group benefit contract is issued determine the mandated coverage.


BENEFIT APPLICATION

Subject to the terms and conditions of the applicable benefit contract, routine costs associated with qualifying clinical trials are covered under the medical benefits of the Company's products.

Description

ROUTINE COSTS

As used in this policy, ​routine costs include items and ​services covered under the benefit contract that would typically be provided according to the standard of care for the diagnosed disease in the absence of the qualifying clinical trial  (​Benefit language​).

In addition, routine costs may include the following, unless covered by the study Sponsor: 

  • Items and services and supplies required solely for the provision of the biological product, device, drug, medical treatment, procedure, or therapy under investigation in the clinical trial​ ​investigational item or service.
  • The clinically appropriate monitoring of the effects of the biological product, device, drug, medical treatment, procedure, or therapy under investigation investigational item or service in the clinical trial that is required for the prevention of complications during the c​linical trial
  • Items or services and supplies required for the diagnosis or treatment of medical complications arising from the provision of the biological product, device, drug, medical treatment, procedure, or therapy under investigation investigational item or service in the qualifying clinical trial​

​​​​Examples of routine costs may include, but are not limited to, the following:
  • Office/outpatient visits
  • Routine laboratory tests
  • Imaging studies
  • Echocardiography
  • Electrocardiogram​
CLINICAL TRIAL

A clinical trial, also referred to as clinical research or a clinical study, is a research study with human volunteers to test new methods of screening, prevention, diagnosis, or treatment of disease. These studies are conducted by physicians and other health professionals in a controlled environment​ to help determine the safety and efficacy of biological products, devices, drugs, medical treatments, procedures, or therapies to improve health.

​A qualifying clinical trial, as defined by the Company, is the systematic, intensive investigation or evaluation of a biological product, device, drug, medical treatment, procedure, or therapy that meets all of the following requirements:
  • It investigates a service that falls within a benefit category of a Company benefit contract.
  • It is not a benefit contract exclusion. ​​
  • It does not unjustifiably duplicate existing studies. 
  • It is designed to collect and disseminate reliable evidence and answer specific questions being researched in the trial.​
  • It is designed and conducted according to appropriate standards of scientific integrity. 
  • It complies with federal regulations relating to the protection of human subjects. ​
  • It is conducted by a participating provider in a participating facility, unless otherwise pre-approved by the Company. 
  • It is being studied in a Phase I, II, III, or IV clinical trial in relation to the prevention, detection or treatment of cancer or other life-threatening disease or condition. ​(
In addition, the qualifying clinical trial must meet one of the following requirements:
  • It is funded by, or supported by, centers or cooperative groups that are funded by one of the following:
    • ​National Institutes of Health (NIH)
    • Centers for Disease Control and Prevention (CDC)
    • Agency for Healthcare Research and Quality (AHRQ)
    • Centers for Medicare and Medicaid Services (CMS)
    • Department of Defense (DOD), Department of Veterans Affairs (VA) or Department of Energy
  • It is being conducted under an IND application reviewed by the FDA or is an IND exemption as defined by the FDA.
  • It is being conducted under an Investigational Device Exemption (IDE).
Clinical trials involving drugs or biological products are classified by the US Food and Drug Administration (FDA) and are designated by the following terms:
  • Phase 0 (zero): Preliminary exploration of an investigational new drug (IND) clinical study that involves limited human exposure and no therapeutic or diagnostic intent (e.g., screening studies, microdose studies)
  • Phase I: Initial clinical studies to determine the metabolism and pharmacologic actions of drugs in individuals, the side effects associated with increasing doses, and the early evidence of effectiveness; may include healthy participants and/or individuals with the disease or condition under study
  • Phase II: Controlled clinical studies conducted to evaluate the effectiveness of the drug for a particular indication(s) in individuals with the disease or condition under study and to determine the common short-term side effects and risks of the drug
  • Phase III: Expanded controlled and uncontrolled clinical trials conducted after preliminary evidence has been obtained to suggest the effectiveness of the drug; also intended to gather additional information to evaluate the overall benefit-risk relationship of the drug and to provide an adequate basis for labeling
  • Phase IV: Post-marketing clinical studies to delineate additional information, including the drug's risks, benefits, and optimal use​
Reliable evidence is classified as any of the following: 
  • Reports and articles published in the authoritative medical and scientific literature
  • Written protocol(s) used by the treating facility or the protocol(s) of another facility studying substantially the same biological product, device, drug, medical treatment, procedure, or therapy
  • Written informed consent used by the treating facility or by another facility studying the same biological product, device, drug, medical treatment, procedure, or therapy
The term experimental/investigational (E/I) is defined by the individual's product or plan.

References

Centers for Medicare & Medicaid Services (CMS). CMS Manual System. Pub 100-04: Medicare Claims Processing. Transmittal 1723. Insuring only clinical trial services receive fee-for-service payment on claims billed for managed care beneficiaries. [CMS Web site]. 10/01/2009. Available at:http://www.cms.gov/transmittals/downloads/R1723CP.pdf. October 18, 2023​.

Centers for Medicare & Medicaid Services (CMS). Medicare National Coverage Determinations Manual. Routine costs in clinical trials: Chapter 1, Part 4, §310.1. [CMS Web site]. 07/09/2007 (Rev. 173, Issued: 09-04-14, Effective: Upon Implementation of ICD-10). Available: https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/downloads/ncd103c1_part4.pdf. October 18, 2023​.

Company Benefit Contracts.

National Cancer Institute (NCI). National Institutes of Health. Dictionary of Cancer Terms. Clinical trial. [NCI Web site]. N.D. Available at: https://www.cancer.gov/publications/dictionaries/cancer-terms/search/clinical trial/?searchMode=Begins. Accessed October 18, 2023​.

National Institutes of Health (NIH). U.S. National Libarary of Medicine. [ClinicalTrials.gov Web site]. Last reviewed December 2014. Available at: https://www.nih.gov/health-information/nih-clinical-research-trials-you/finding-clinical-trial. Accessed October 18, 2023​.

National Cancer Institute (NCI). National Institutes of Health. NCI Dictionary of Cancer Terms.Phases I, I/II, II, II/III, III, IV. [NCI Web site]. N.D. Available at: https://www.cancer.gov/publications/dictionaries/cancer-terms/search/phase/?searchMode=Contains​. Accessed October 18, 2023​​.

US Food and Drug Administration (FDA). Code of Federal Regulations. Title 21, Vol 5: Food and drugs. [FDA Web site]. Original: 04/01/04 (Revised: 04/01/2020)​. Available at: http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?CFRPart=312&showFR=1. Accessed October 18, 2023.​​

Coding

CPT Procedure Code Number(s)
N/A

ICD - 10 Procedure Code Number(s)
N/A

ICD - 10 Diagnosis Code Number(s)

Z00.6 Encounter for examination for normal comparison and control in clinical research program


HCPCS Level II Code Number(s)
N/A

Revenue Code Number(s)
N/A

Modifiers

Q0 Investigational clinical service provided in a clinical research study that is in an approved clinical research study

Q1 Routine clinical service provided in a clinical research study that is in an approved clinical research study​​


Coding and Billing Requirements


Policy History

Revisions From 07.00.20g:
11/26/2025
This policy has been reissued in accordance with the Company's annual review process.​​
11/01/2023
This policy has been reissued in accordance with the Company's annual review process.​​
07/05/2021This version of the policy will become effective 07/05/2021. The intent of this policy remains unchanged, but the policy language has been updated to further clarify current benefits.​​​

The following modifier has been added to the Coding Table under the Modifier Heading:
Q0 - Investigational clinical service provided in a clinical research study that is in an approved clinical research study

Effective 10/05/2017 this policy has been updated to the new policy template format.
7/5/2021
7/5/2021
11/26/2025
07.00.20
Claim Payment Policy Bulletin
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