Insights,

by Stacey Gilbert, MPH, MBA

The MolDX Technical Assessment: How to Move Your Test from “Not Successful” to Medicare Coverage Success

In the laboratory space, the MolDX Technical Assessment (TA) is often the moment where the gap between “a great test” and a “Medicare covered test” becomes real. Your test’s science may be strong, the innovation meaningful, and the clinical unmet need obvious, yet you can still complete the process and experience a “not successful.”  TA. When that happens, it can feel more like a defeat than receiving the gift of purposeful feedback.

It isn’t.

At ADVI Health, we help labs navigate MolDX with a clear understanding that the TA is not only an evidence review, it’s a trusted reimbursement decision framework across four Medicare Administrative Contractors’ jurisdictions. We’ve seen repeatedly that fastest path to Medicare coverage is rarely about getting “more data.” It’s about having the right data, organized around how MolDX evaluates analytical validity (AV), clinical validity (CV), and, most critically, clinical utility (CU) in the context of real-world coverage expectations.

I’ve penned this post to explain how labs can build a MolDX-ready strategy, what commonly causes TA outcomes to miss the bar, and how to create a practical plan to achieve Medicare coverage…even after an initial TA doesn’t land as expected.

The MolDX Approach: The Program Rewards Evidence That Changes Care

MolDX operates with a clear objective- to ensure that molecular diagnostics billed to Medicare are reasonable and necessary, supported by evidence that the test performs reliably and, importantly, drives decisions that have an influence on a patient’s health outcome.

Sometimes we see labs approach the TA process like this: present the totality of evidence, demonstrate novelty, and trust that the test’s value is self-evident. MolDX assesses value differently. We consistently see reviewers asking:

  • Can your test be reliably performed and reproduced?
  • Does the result meaningfully stratify patients in a clinically credible way?
  • Does the result change management in a way that improves outcomes (or avoids unnecessary interventions) for a defined Medicare population?
  • Is the intended use case properly bounded by indication, population, specimen type, and care pathway?

If those elements aren’t tightly aligned, the TA may not be successful even if the test is truly unique.

A Common Misconception: AV and CV Win Attention…CU Wins Coverage

Most labs can deliver a clear AV and CV story. Where we see TAs most often struggle is with clinical utility. It’s not because the test doesn’t have value, but because CU has to be framed in a way that aligns with payer logic and real-world decision-making.

What MolDX tends to reward in CU

MolDX-friendly CU narratives often include:

  • A clear intended use tied to a specific decision point (e.g., escalation/de-escalation, therapy selection, surveillance intensity, treatment start/stop).
  • A defined clinical pathway: what clinicians do today, what changes with the test, and why that change matters.
  • Evidence that the test reduces uncertainty and avoids harm (ex. unnecessary procedures, ineffective treatment(s), toxicity, cost, downstream utilization).
  • Outcome(s) are tied to patient benefit, not simply “risk prediction” or “statistical correlation.”

Where do labs get “stuck” on CU most often?

We frequently see CU fall short when:

  • The test predicts risk but doesn’t specify what clinicians should do differently.
  • Studies show association, but the care pathway is not standardized enough to demonstrate actionability.
  • Evidence is strong in a general population but not anchored to Medicare-relevant cohorts.
  • The intended use drifts or expands too broadly (ex. multiple indications, endpoints, or settings) and the story loses clarity.

Bottom line: even with a clear intended use, if the reviewers can’t clearly connect results → actions → outcomes, CU becomes a liability.

What a “Not Successful” TA Often Really Means

A “not successful” TA is not stating your test is “bad.” More often, reviewers are signaling that:

1) The test’s evidence doesn’t match the claimed use.

The submission may include good studies, but not for the exact intended use, population, or clinical decision you’re asking Medicare to cover.

2) The clinical pathway isn’t sufficiently defined.

Even strong CV misses the mark if reviewers don’t see a consistent, guideline-aligned management action that follows the result.

3) The story is too broad.

A multi-indication, multi-endpoint strategy can be tempting, especially for platform technologies. But we’ve clearly witnessed that early TA success comes from indication discipline. A “not successful” outcome should be treated as a chance for a strategy reset, not an outright rejection.

A Practical Coverage Path After TA: Pause, Reflect, and Course Correct- Don’t Start Over

When labs come to ADVI post-TA and frustrated with an unsuccessful outcome, our first priority is to figure out what is needed to “reset the table”…separate what needs refinement from what needs repositioning. The goal isn’t to rebuild everything-it’s to build a coverage-aligned plan, based on how the reviewers understand and assess AV, CV, and CU evidence.

A typical ADVI course-correction roadmap includes:

Step 1: Diagnose the gap.

  • What did MolDX view as the AV/CV/CU weakness?
  • Was the issue the evidence itself, or how it was framed?
  • Is the intended use too broad or mismatched to the data?

Step 2: “Re-anchor” to an actionable use case

  • Identify a clinical decision point with clear downstream actions.
  • Confirm that the pathway is realistic, provider-accepted, and ideally guideline-adjacent.
  • Align endpoints to payer-recognized outcomes (avoided interventions, improved response selection, better surveillance efficiency, reduced toxicity)

Step 3: Build a CU strategy that is credible to the payer.

This might mean:

  • A management change study (prospective or pragmatic)
  • Real-world evidence plans with pre-specified outcomes.
  • A “treat-to-target” design when longitudinal decision-making is central.
  • A phased evidence strategy where early coverage supports broader expansion later.

Step 4: Package the submission for how MolDX evaluates evidence.

Even robust evidence can underperform if the submission:

  • doesn’t map clearly to AV/CV/CU
  • lacks consistent definitions for intended use and population.
  • under-explains the care pathway and real-world actionability.

TA success is as much about structure and alignment as it is about statistics.

How ADVI Helps Labs Win with MolDX

ADVI supports labs at each stage of the journey: before the TA, during development, and after outcomes that require a strategic pivot or resubmission. Our work is grounded in a “reimbursement-first” mindset: what will be persuasive to the reviewers, defensible to payers, and adoptable by clinicians.

Our MolDX support commonly includes:

  • TA readiness: evidence mapping, indication discipline, AV/CV/CU gap analysis.
  • Clinical utility strategy: study design, endpoint selection, clinical pathway definition
  • Payer positioning: aligning intended use to guidelines, standard of care, and real-world practice.
  • Post-TA recovery: course correction plan, resubmission strategy, evidence sequencing roadmap.
  • Preparation and attendance at MolDX informal meetings
  • Product dossier review and feedback
  • TA draft submission review and feedback.

We’ve worked across numerous TA’s, confidently stepping in exactly where labs need help translating promising science into payer-ready evidence.

What Should Your Lab Be Doing Right Now?

If you are approaching a TA submission or reassessing your game plan after a challenging outcome, here are four questions that can rapidly clarify your next best move:

  • What is the single most defensible intended use that can win first?
  • Can you clearly describe what a clinician does differently after receiving the result?
  • Do your endpoints show patient benefit or avoided harm-not just correlation?
  • Is your Medicare population explicitly supported in your evidence story?

Is Your Lab Ready to Strengthen Its MolDX Strategy?

If you’d like a structured assessment of your MolDX readiness or if you need a post-TA recovery plan to get back on track, ADVI can help you identify the most efficient path to Medicare coverage success. Get in touch and let’s talk.

Interested in getting in touch with Stacey?

Stacey Gilbert, MPH, MBA

Director, Precision Medicine