Is it Getting Much Harder to Obtain Your Own Code? What Recent Data Suggests
Nicole Coustier has over 20 years of experience in U.S. Reimbursement and Market Access and has helped early-stage MedTech achieve widespread reimbursement coverage in the U.S.
Three application deadlines a year.
Three decision meetings a year.
A review of the last nine AMA CPT Editorial Panel meetings, from February 2023 through September 2025, shows a clear trend: the Panel is tightening standards. The most recent meeting in September 2025 continued the pattern: fewer approvals, more withdrawals, and greater scrutiny of emerging technologies, particularly those seeking to convert from Category III to Category I.
For early-stage MedTech and digital health companies, this is a signal to start earlier and build reimbursement planning into the product development timeline.
Recent Trends in CPT Panel Actions (2023–2025)
Across nine meetings, the AMA’s Summary of Panel Actions shows the following patterns:
Approval rates are declining. Category I and III acceptances have dropped from roughly 35–40% in 2023 to about 20–25% in 2025.
Withdrawn applications are increasing. More sponsors are pulling items before the Panel vote, often after informal signals that the evidence or clinical adoption data aren’t strong enough yet.
Category III to I conversions remain difficult. Few technologies move successfully into permanent code status without significant real-world use and enough peer-reviewed evidence.
AI and algorithmic technologies face higher scrutiny. Validation, transparency, and reproducibility remain sticking points.
More emphasis on guideline revisions. The Panel is prioritizing clarity and consistency over code proliferation.
What This Means for Early-Stage Companies
For innovators developing new technologies, these findings underscore one key point: reimbursement planning can’t wait until commercialization.
Early-stage teams should:
Start CPT strategy early. Coding pathways should be assessed during or even before pivotal trial design.
Plan for interim Category III coding and coverage. Category III codes can be valuable, but require proactive communication with payers and societies to drive utilization data.
Align evidence generation with payer expectations. The clinical data that support FDA authorization often differ from what the CPT Panel and payers view as meaningful.
Seek experienced guidance early. Advisors who understand both CPT process mechanics and payer policy dynamics can help you time your submissions and build the right story.
Your First Step
The CPT process may be increasingly unfriendly to innovation, but the Panel would argue it’s becoming more disciplined. Early-stage medtech companies that treat coding and reimbursement as strategic building blocks rather than late-stage milestones will be far better positioned for success.
If your team is beginning to think about coding strategy or evidence alignment, it’s worth starting the conversation now, well before you’re ready to file.
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