Home / Transcripts / COMPASS Pathways plc (CMPS) · July 11, 2023

COMPASS Pathways plc (CMPS) Earnings Call Transcript

July 11, 2023

NASDAQ US Health Care Biotechnology special 55 min

Earnings Call Speaker Segments

Operator operator
#1

Good day, and thank you for standing by. Welcome to the CPT III Code Language Discussion conference call. [Operator Instructions] Please be advised that today's conference is being recorded. I would now like to hand the conference over to Stephen Schultz, Senior Vice President of Investor Relations. Please go ahead, sir.

Stephen Schultz executive
#2

Yes. So good day, and welcome, everyone, and thank you for joining us for this program on the newly issued CPT III Code language. Again, I'm Steve Schultz, Senior Vice President of Investor Relations at COMPASS Pathways. Before we begin, let me remind everyone that during today's event, the team will be making forward-looking statements within the meaning of the Private Securities Litigation Reform Act of 1995 as amended including statements about our commercial plans and potential reimbursement and our ability to obtain regulatory approval to launch and successfully commercial COMP360 psilocybin therapy. You should not place undue reliance on these forward-looking statements. Actual events or results could differ materially from those expressed or implied in any forward-looking statements as a result of various risks, uncertainties and other factors including those risks and uncertainties described under the heading Risk Factors in our filings with the SEC Additionally, these forward-looking statements represent our views only as of today and should not be relied upon as representing our views as of any subsequent date. We specifically disclaim any obligation to update or revise any forward-looking statements even if our estimates or assumptions change. Also, please note that the opinions of our guest is theirs and not necessarily that of COMPASS Pathways. At the conclusion of this call, we'll take questions. And at the conclusion of the program. If we are unable to get all the questions in, or you would like a meeting with management, please reach out to me directly. With that, I'm pleased to introduce Kabir Nath, COMPASS Pathways' CEO.

Kabir Nath executive
#3

Thank you very much, Steve, and let me add my welcome to everyone for joining us for today's webinar. On the recently released language of the CPT III code. This code, as you know, is for continuous in-person monitoring and intervention during psychedelic medication therapy. As you know from our recent press release, this code will go into effect and will be published in the CPT manual from January 1, 2024. You might be surprised and think it's a bit hyperbolic that we described the creation and approval of something as apparently mundane as a CPT code as exciting, but we truly are excited by this development. This code is going to play a crucial role to facilitate reimbursement and support broad and equitable access to psychedelic treatments if they receive regulatory approval. This is critical for people who are in urgent need of new options for difficult-to-treat serious mental health issues such as treatment-resistant depression and anorexia nervosa and post-traumatic stress disorder. So we're delighted also to welcome to this discussion today to esteemed guests from both the payer and the provider communities, and I look forward to the discussion. So with that, let me now hand over to today's moderator, Chris Williams, our Chief Communications Officer, here at COMPASS Pathways. Chris?

Christopher Williams executive
#4

I think we're having a bit of a technical difficulty there. I'll proceed... [Technical Difficulty] My apologies for that. Engineer, can you disconnect that line, please? Well I hope it's disconnected now, again, apologies for that. We are having some technical difficulties today. But we want to introduce our panelists. We have Dr. Geoffrey Grammer, Chief Medical Officer at Greenbrook TMS Centers who represent provider point of view. I hope we have Dr. Marketa Wills right now, Chief Medical Officer at Johns Hopkins HealthCare. who will offer a payer's perspective on the CPT III code. We've had some technical difficulties getting Marketa connected today. So we'll see if she's able to participate as planned. And then finally, we have Dr. Steve Levine, our colleague here at COMPASS Pathways, who is Senior Vice President for Patient Access and Medical Affairs. Let's get into the conversation right away. And I think what I better view is start by first putting a question to Steve, since I know I have them here in front of us and he can hear me. Steve, can you briefly remind us what CPT codes are and what role they play in the delivery of health care in the United States.

Steve Levine executive
#5

Thank you, Chris. Yes, I can hear you. And CPT codes are a common language for doctors and other health care professionals to describe and report medical services and procedures accurately and efficiently to facilitate reimbursement by payers. Essentially, anytime health care providers and patients interact, CPT codes are involved.

Christopher Williams executive
#6

Great. Thanks, Steve. Geoff, let's go to you. We're curious to get your kind of high-level take on the language of the CPT III code for psychedelic therapies now that it's been released. From your perspective, as a provider, why don't you tell us a little bit about what having the CPT code means and how it'll create access for a therapy for patients? What is the [indiscernible] for you in your centers?

Geoffrey Grammer attendee
#7

Yes. I mean this is a big step because when you're doing a treatment modality that requires observation after administration of a compounder substance, you need to be able to model some method of doing that. So the drug is one expense, and that has its own pathway towards coverage, but a big piece of that is going to be some sort of compensation for the facility or a provider who is overseeing that administration. Without both of those things satisfied, you can't create the systems needed to deliver the treatment to the patients who need it.

Christopher Williams executive
#8

And Geoff, let's stay with you. Can you give us a recent example where not having a code that would have this kind of language made it difficult or maybe even impossible for you to deliver an approved therapy because there wasn't any existing code that you could work with?

Geoffrey Grammer attendee
#9

Yes. Thank you. I mean it's interesting. So Greenbrook TMS has 133 centers around the country, and we sort of specialize in taking treatment modalities and bringing them to the patients who need it. And when we think about the barriers to that, I usually think of three things that need to be satisfied. You have to have awareness. You have to have some geographic proximity to be able to access that modality such while we have centers in a lot of places. But the third piece is the fiscal viability. The reality is most patients who would need this treatment cannot afford sort of a fee-for-service cash-only model and it keeps them financially separated from that treatment. So if we go back to both TMS, just transcranial magnetic stimulation and Spravato, we saw launches of launches for both of those that were in a way stagnated, probably worse with TMS because all those things weren't necessarily satisfied. It was unclear where they were kind of deploying these devices, who's going to be doing the treatment delivery and how those will be coded and build. And so without that CPT code, you can't begin to even talk with payers to come up with a model for compensation that makes this sort of viable, if you will. And with Spravato as well, we saw trying to take existing codes and mesh it to what was a very unique treatment and it took a while to kind of figure that out. By doing this on the front end, and making it specific for this treatment modality, I think one, it speaks to just how revolutionary this is going to be; and two, it allows you to do that prep work so that when or if you have approval on launch day 1, you already have all those systems in place that people then don't have to invent for the first time. So it is going to accelerate the deployment and the adoption of this much more quickly than I think we have seen with other novel treatment modalities.

Christopher Williams executive
#10

Great, Geoff. Marketa, are you on the line now? It seems as though we don't have Marketa, still having some technical challenges there. We apologize for that. So maybe let me build off of what we just heard from Geoff and turn to Kabir and Steve. Steve will start with you as our formal panelist. Can you talk a little bit about the COMPASS' perspective on this then, looking ahead to a potential commercial launch for us in COMP360 psilocybin treatment. Why is this code important for us?

Steve Levine executive
#11

We're focused not just patient access for those who may benefit from COMP360's dose therapy, if approved, and among other factors in creating that access, the delivery of the psychological supports must be financially viable for health care providers. So this is a critical step for patient access and commercially and really a proof point if this is possible.

Christopher Williams executive
#12

Kabir, anything you want to add to that?

Kabir Nath executive
#13

No. I think what I would add is also, I think what's really important is what Geoff noted, which is doing this work so far in advance is really enabling us to be in a place where the infrastructure, the ability to actually deploy this code and ultimately potentially have it as a reimbursable code. By the time the launch is really, really important. And again, I think it's a great example of where, as we say at COMPASS, we've designed things from kind of the end state back to make sure we're ready for that commercialization if we are indeed approved.

Christopher Williams executive
#14

Great. Thank you, Kabir. Let me try again to see if we have Marketa. So far, been a fairly glitchy conversation, which is no fault of yours. We're glad that we're able to finally get you into the conversation. And just in the nick of time, as I have a couple of questions for you. So if you're ready, I'm going to fire away.

Marketa Wills attendee
#15

I am ready. Thanks for having me on this morning.

Christopher Williams executive
#16

Great. So let's -- I'm going to throw to you the same question that I started off with -- on with Geoff, which is to just get your perspective at kind of a high level about the approval of the CPT III code for the administration of psychedelic treatments. And what's your reaction to it? And maybe you could also tell us a little bit about when you see a code like this a new code, what is it that you're looking for? And what are you looking to track?

Marketa Wills attendee
#17

Yes. Thank you so much for the question and the backdrop. Here in the plan setting, when new codes are released, particularly the CPT III code, we have a team of folks who really go in and comb through the literature, the evidence to really understand how to price through investigational, experimental and yet to be released in the managed care setting. Our main touch competitive landscape touch point is often CMS and Medicare. We keep a close eye on the competitive landscape around codes and pricing. But as new CPT III codes emerge, we're often eagerly anticipating how we'll process through investigational, experimental and yet-to-be-released modalities against all of our other offerings from the plan.

Christopher Williams executive
#18

Marketa maybe if you could pick up on this theme of kind of flexibility and granularity in the code. What does that facilitate for a payer?

Marketa Wills attendee
#19

Yes. As we think about what all is included in the code, whether or not services are bundled or disaggregated, it allows us to more appropriately price for the services in under consideration. So to the degree that various pieces can be bundled or pulled out, it allows us to really think through alternatives versus alternatives to treatment. I think another important point in this particular offering that we're excited about is that we know that treatment-resistant depression really impact the degree to which other physical health modalities are addressed and physical health conditions are addressed and taken care of. So our numbers show us over and over again that if someone has treatment-resistant depression and has, for example, a cardiac condition, the costs are going to be much, much more. So when we think about the actuarial consideration around pricing we take into account the total cost of payer. So, we are very excited about this coming forward to the benefit of our membership.

Christopher Williams executive
#20

Marketa, let me ask you a follow-up question, and I want to pick up, I think, on something that we heard from Geoff earlier, who gave us and talked through little bit about the challenge of trying to administer some of these treatments when there wasn't a CPT code in place to clearly facilitate that. Is that a challenge from a payer perspective as well? Or was that a challenge -- has that been a challenge from a payer perspective as well?

Marketa Wills attendee
#21

Oh, certainly, certainly, almost to the point where we're not really able to reimburse when there's no CPT code. CPT codes are certainly sort of the gold standard by which we take through our, what we call internally our source of truth on how we -- our payment strategy across all of our lines of business. And so without ICD-9, 10 or 11 codes as well as CPT codes, we're just not able to do that. It really is a critical enabler for us to be able to move forward with our plan offerings.

Christopher Williams executive
#22

Great. Thank you very much for that. We've got a number of people on the line who I think probably are going to want to ask some questions as well. So I think we'll wrap up the moderated discussion here. But before I turn it back over to Steve, Steve Schultz, for his bringing in the analyst questions and Kabir for some closing thoughts. I just want to ask Geoff, Marketa, if you have any closing thoughts as we wrap up this portion of our program today. Geoff, why don't we start with you. I think Geoff maybe is having trouble hearing me.

Geoffrey Grammer attendee
#23

Can you guys hear me?

Christopher Williams executive
#24

Yes, yes. We got you there.

Geoffrey Grammer attendee
#25

All right. Good. Sorry, but that wouldn't let me unmute. So yes, what I would say is this, I mean, this is exciting, right? And we're seeing the field of psychiatry change, our behavioral health change pretty substantially. The era of psychotherapy and medications being the base of all treatment is beginning to evolve into something much more sophisticated. And I equate it to the difference between office-based cardiology and interventional cardiology. The two need to work hand in hand together to be able to better help their patients. And companies like Greenbrook are trying to fill that need. And with this evolution, what it allows us to do is begin to build in the systems and processes now in our company at Greenbrook. Literally, the facilities, the logistics, the staffing, the modeling, putting the financial models together to figure out how to get this to the patients who need it. If we look at the need for treatment-resistant depression, we are talking millions of patients, 1/3 of people who get treated with medications and/or therapy will not have an adequate recovery. And you're talking prevalence rates of depression in the U.S. being between -- depending on which stats you look at, 7% up to almost 20% during the pandemic. So you were talking a huge number of people with needs and we now are in a position where we don't have to wait for approval of launch to begin to build the systems. We can do it today so that when the time does come, we can help those patients who are seeking out this therapy.

Christopher Williams executive
#26

Geoff, thanks very much. Marketa, any closing thoughts from you before I hand to Kabir?

Marketa Wills attendee
#27

Thanks for that opportunity. I'd echo the previous panelist's comment. This is a game changer for the field of psychiatry. And it will allow us to think differently about how we think of total cost of care for physical health and behavioral health interventions. I, for one, am excited about this opening up. I'm excited about access for all communities, whether they be low-income communities in Medicaid or Medicare, commercial populations as well. And so I think that this modality is going to be certainly a game changer that unlocks treatment for folks who were having limitations being treated with medications and therapy.

Christopher Williams executive
#28

Marketa, thank you, Geoff, Marketa, thanks to both of you for joining us in our conversation today. And I'll ask that you stay with us for the Q&A portion of today's program. Let me ask Kabir for some closing comments before we take it back to Steve Schultz. Kabir, I don't think we've got your audio. I can't hear Kabir. Kabir, you want to give it 1 more shot?

Kabir Nath executive
#29

Yes. Can you hear me now?

Christopher Williams executive
#30

We got you.

Kabir Nath executive
#31

Yes, about it. No first, thank you very much to Geoff and Marketa for joining us. And I think just a couple of salient points to pick up. I think you use words like revolutionary and game changing, and that's certainly how we see the potential for psychodelic therapies if they are approved. I think the other thing was, thank you again to both of you for reminding us that the urgent need, the unmet need. Certainly, the prevalence of treatment-resistant depression, the fact that so many people with depression will unfortunately progress to not being served well by current treatments and also the extensive comorbidities that this is not just a disease that you can see in isolation. And so again, as I said at the start, we truly are excited. I'm proud of the fact that we, together with MAPS PBC led this work in a very early way in order to allow folks like Geoff and indeed Marketa to do the work in their different institutions that prepares for the potential approval and launch of these. So again, very excited about it. And I think another key example of the building blocks we and COMPASS are putting in place for success in the long run.

Christopher Williams executive
#32

I'm told that Steve Schultz is with us even though I can't see him. So Steve, if you're there...

Stephen Schultz executive
#33

Can you hear me Chris?

Christopher Williams executive
#34

Yes, we got you, Steve. Great. Thanks. Glad to hear you. Let's turn it over to you for the Q&A.

Stephen Schultz executive
#35

All right. Good. I apologize for not being on video, but I'm sure all of you have seen enough of me. So let me begin with questions. I will start with Patrick Trucchio of H.C. Wainwright & Co. Patrick, go ahead.

Patrick Trucchio analyst
#36

Congrats on getting the Category III CPT code through the system well in advance of the potential launch of COMP360. If we look ahead post approval, COMPASS would still need a category I CPT code, which could take 1 to 3 years to receive. So our understanding is that having this category III CPT code may accelerate the timing. So for the panel, then a few questions. First, is this understanding of this transition from the Category III to Category I CPT codes correct? Secondly, can you discuss how you would go from having a Category III CPT code to a Category I CPT code? What is the difference between these codes? And ultimately, how do you accelerate it from maybe what was seen with Spravato or TMS or some of these other examples, how do you accelerate that timing? And what's the -- ultimately, how much does having this category III CPT code now accelerate this launch for COMP360, assuming it's approved in a few years?

Steve Levine executive
#37

Is that what I should take?

Kabir Nath executive
#38

Yes.

Steve Levine executive
#39

That's a great question, Patrick. So I think this partly relates back to something that Geoff was touching on earlier, and this was around the urgent needs that exist right now for these patients, the work that needs to be done in order to create this access. And the fact that a lot of that work can start now even ahead of approval. This is a perfect example of that. We -- there is no access without FDA approval. Let's just start there, right? There is no shortcut to that. We are committed to the rigor of conducting the studies that will get us to that approval. At the same time, I think we need to have some confidence in the likelihood of that approval. And with that, to begin all the work that we can do now rather than waiting until approval and therefore, having delays potentially to patient access. So this is a perfect example of that. by applying for and receiving the Category III codes now, we can start that clock earlier on that required time. And Patrick, as you mentioned, that often can be 1 to 3 years post the issuance of a Category III code or post the approval of a product. One of the criteria for moving from Category III to Category I is sufficient reporting of that code and usage of that code in the community so that health care providers can be surveyed as to the work being done to deliver these services and the value can be applied to the code when it's issued. In the case of this code that's just been approved, it's 0820T. It is not specific to our product or to any particular indication. It can be used across a range of product services and indications. And so early applications of this code may be to ketamine-assisted therapy? Or should MAPS have their product approved for PTSD, which may come before us, this code will already start to be used. And because there's likely a few years prior to our potential approval and launch, there is likely to be sufficient usage of this code such that we can more quickly move towards that category I code and potentially even prior to our launch.

Patrick Trucchio analyst
#40

Got it. And then I think in the past, you've talked about the need for education initiatives to make sure service providers are aware of the codes existence and its eventual use with psychedelic therapeutics. So my question for the panel is what are the best ways to make service providers aware of the category III CPT codes existence?

Kabir Nath executive
#41

If Geoff or Marketa, you want to weigh in on that, please. That would be great to get your perspective.

Geoffrey Grammer attendee
#42

Yes, can you guys still hear me okay?

Patrick Trucchio analyst
#43

Yes, we can.

Geoffrey Grammer attendee
#44

Okay. Good. Sorry, the mute button on the software here is not indicating on or off, so I'm never sure what's status I am in. So, I actually don't think that when that launches, that's going to be as big of an issue in the psychedelic community for a couple of reasons, right? Honestly, when there's a new modality that comes out like this, you're going to have service providers you're basically like how -- what are the methods by which we're supposed to communicate with payers on this and it's like here's the code for this individual modality. I'm not going to speak to Compass's launch, but I'm sure it's not going to come without its own fair, robust outreach to improve awareness within the medical community and with patients. And when companies do that, they typically will fold in this information when it's relevant to that particular modality. So yes, I honestly think the uptake on that of all the things we're going to have to worry about that, at least on the service provider side, that's probably going to be much less of a hurdle than other things.

Marketa Wills attendee
#45

And jumping in, certainly, professional organizations such as the American Psychiatric Association, American Psychological Association are -- as well as MAPS, the group focused on psychedelics drugs, work with provider community to sort of prime them for as new technologies and things emerge. So I think those kinds of professional society organization are well poised to help sort of get the word out and get providers notified and educated. And I think that's an important piece of that, too. Obviously, training and trainees will need to be a part of that as well. Thank you.

Kabir Nath executive
#46

Thanks very much, Marketa. Thanks, Patrick, for the questions. I think, Steve, we can move on.

Stephen Schultz executive
#47

Absolutely. Thank you, Patrick. The next question comes from Neena Bitritto-Garg of Citi.

Unknown Analyst analyst
#48

It's [indiscernible] on the line for Neena. I was sort of wondering could code cover -- I guess, I'd say if there are multiple patients going through therapy at the same time, could the code cover all of them that the physician could only report 1 hour, if they're monitoring multiple patients or could they, in theory, report the code for each patient? And in addition, does this also include the integration session or just a dosing?

Kabir Nath executive
#49

Thanks, Steve, if you could take those, please?

Steve Levine executive
#50

Yes. That sounds like one for me. So as a reminder, this therapy is delivered in three components, there are preparation sessions and administration day and then integration sessions. The administration day being the only one where there is drug involved. Preparation and integration sessions, even though our model is not psychotherapy, or covered by existing psychotherapy codes. And so the gap that this new code is addressing is the psychological support delivered on the day of administration and that psychological support code or new code does not preclude also reporting a medical code and an evaluation management code on the same day. This code -- initially, the first code itself describes one therapist in the room with the patient providing that support and the two sub-codes allow for a second health care provider in the room or the involvements of medical staff. To your question, this code does allow for simultaneous administration to multiple patients, a scenario that would be covered by this code is multiple patients being treated simultaneously with an appropriate therapist in the room with each patient with a physician or other appropriate prescriber supervising who is available. And so as you can see with this, along with the ability to report this on an hour-by-hour basis, there really is a lot of granularity involved in the reporting here to allow for a number of different scenarios, including simultaneous administration.

Stephen Schultz executive
#51

And the next question comes from Frank Brise from Oppenheimer.

François Brisebois analyst
#52

You hear me okay?

Stephen Schultz executive
#53

Yes.

François Brisebois analyst
#54

Is the timing surprising here of this approval or has there been precedence in this field of psychiatry, where this has happened so early in advance? And then maybe I'll just loop in the second one quick is, I was just wondering, in terms of the FDA guidance that came out recently, I was wondering if you guys wanted to comment on what you thought it could mean for COMPASS. And would it help actually for this coding if someone else like MAPS was approved earlier? And how does the guidance maybe affect MAPS. I don't know if you're willing to comment on any of those.

Kabir Nath executive
#55

So Geoff, perhaps if I could ask you because I think you commented on how doing this early in this case is very valuable, but you can give your perspective on some other innovations in psychiatry and whether this has happened before?

Geoffrey Grammer attendee
#56

To my knowledge, I mean I think this is actually unique. And I think it's -- and I could -- I think it's unique, honestly. And I think it's from a couple of things. I think number one, it talks about the paradigm shift that we're seeing in psychiatry, where we're shifting off of kind of traditional things into interventional psychiatry and in particular, this emerging world of psychedelics, and that's incredibly refreshing. But that's unique. That hasn't happened. I mean if we look back in the world of psychiatry, we had medicine therapy in ECT for a number of years. And then it was really TMS therapy that came along that was sort of the first into this interventional psychiatry on a kind of large-scale basis that they moved into Spravato and nasal Esketamine, as the next. And so it seems to me like what's happening, and I don't -- I'm not in the room with COMPASS Pathways and all, but what I think what's happening is they had the wisdom to look back at those launches and said, "Well, what can we learn from this." And I think the field of psychedelic therapy also has done the same thing. And so I think this is unique and that is being done early. I think it is the right answer. I think it's because of the lessons learned from other launches.

Kabir Nath executive
#57

Thanks for that, Geoff. And to the second part of the question, I mean, as you're aware, this work was undertaken in collaboration with MAPS PBC. So while I obviously can't comment on their strategy or their plans or their regulatory strategy or anything else. Certainly, from a use of the code, I mean, we would expect MAPS PBC to be doing so should they be approved? Steve, I don't know if there's anything you want to add on that?

Steve Levine executive
#58

To us, their usage of that code is very favorable to us and to the field, it does help to start to establish the tracking of the use of the code and move it along towards the conversion to Category I.

François Brisebois analyst
#59

I don't know if you can -- can you still hear me?

Kabir Nath executive
#60

Yes.

François Brisebois analyst
#61

I was just wondering if you wanted to comment on the FDA guidance for psychodelic drug development that came out recently and if there is any impact here?

Kabir Nath executive
#62

Sure. So no. I mean, I think what we've said is that we were not surprised by anything in that. It was very much aligned with what we already understood of the agency's thinking. And in fact, if you drill into it, the description of what would be an acceptable Phase III program, well, you'll find it very much describes the COMPASS Phase III program. So no, we don't see any need to make any changes to our trial designs and so on. And finally, we're actually delighted to see those guidelines out. I think they are actually a significant advance for the full sector and a sign of the FDA is very deep. Engagement with this sector, recognizing the complexities. And just as a reminder, of course, we have been in dialogue with the FDA around COMP360 for a close to 6 or 7 years by this stage.

Stephen Schultz executive
#63

Next question comes from Elemer Piros of E.F. Hutton Elemer.

Elemer Piros analyst
#64

This question may be best addressed to Marketa. Marketa, you mentioned that you would look at a number of factors then figuring out how to price the code, whether it's psilocybin therapy or MDMA therapy, the administration, the support is certainly more unique or different than administering Spravato or TMS. What sort of factors would go into your pricing decisions there?

Marketa Wills attendee
#65

Yes. I think the amount of training required for the therapist who would support the administration of the drug. The duration of therapy needed. So the time, what would be part of that. The number of therapies needed at any given time So all of those factors would be weighed against the traditional psychotherapy codes and taking a look at. And we make sort of the actuarial determination. We do, as I stated before, look broadly across the marketplace as well when we're making those decisions, but that's sort of the approach that we take, and those would be some of the factors that would go into the therapeutic component of it.

Stephen Schultz executive
#66

Thank you, Elemer. The next question comes from that of Charles Duncan of Cantor Fitzgerald. Charles?

Charles Duncan analyst
#67

Kabir and team, thanks for hosting this webinar. To the two KOLs, Geoff and Marketa, I had a question for you. When you think about the -- I guess, the therapeutic utility of say, COMP360s and potential barriers to adoption, now that the CPT III codes are articulated, I guess I'm wondering, what do you think is the greatest risk in the development of COMP360? Is it clinical execution and/or data such as effect sizes? Is it regulatory? Or are there other nuances in commercialization such as availability of therapists that make you wonder about the potential therapeutic utility of the paradigm.

Kabir Nath executive
#68

Thanks, Charles. I can ask Marketa to go first. And then for Geoff, please?

Marketa Wills attendee
#69

I think many of the factors that you hit on, I think of as the risk. Certainly, as we know, in the mental health field, there is a well-known, well-documented workforce shortage. I think that's changing. I think with the pandemic, one of the things that happened was that mental health and behavioral health became more acceptable and understandable to more people. And so over time, we see more and more students moving towards therapy and psychiatry as a field. And that's exciting, I think, for all of us that mental health has certainly emerged as sort of no longer the stepsister in medicine, but a driver, but I think we're all sort of now intuitively aware of. And so that's exciting. So I think while we may have workforce considerations in the short term, in the medium to longer term, I do believe that we're going to see that pipeline grow. And then, of course, the regulatory concerns. That being said, I think those are being worked through right now. That's going to always be a risk for all medications that are coming off of the scheduled drug list. But that's being worked through right now through the research spearheaded by COMPASS and others. Those I would identify as the two biggest barriers but our risk, but as I stated, I do think that I see a path of very quick path towards mitigation factors for us as a nation. I'll turn it over.

Geoffrey Grammer attendee
#70

Yes. So I'll follow on that. I think I look at the two biggest issues, and you've already touched on the first, which is how do you scale this in a way that makes it accessible to the millions of people that need it, right? And that's where I think companies like Greenbrook that specialized interventional psychiatry are going to be a real key in beginning to develop those clinical care models, including things like staffing and facility, everything else. And again, one nice thing about Spravato already being in the marketplace, it allows for literally brick-and-mortar renovations to -- that we can then extrapolate into, hopefully, the psychedelic marketplace. At least that's how we're approaching it. But the other thing too is diversion out of the classic medical field. If I saw any risk to the psychedelic community, it's going to be that some people may look to the elicit market to try to achieve the same thing, easier achiever. And there are real problems with that involved in things like purity, dosing, safety, supervision, integration therapy and so forth. And certainly, I will tell you in my own practice, I've seen people try to go that route I cannot think of one where that ended up being a durable, favorable benefit for them. So the rigor by which companies are investigating and clarifying these models, I really -- I think it's going to distinctly differentiated from the immature casual consumers of illicitly acquired substances. In other words, it kind of just doesn't work is what I'm seeing. If you don't do it right in a medical setting, never mind the safety associated with that. So if we cannot build it out though, I mean if we can't do what we're doing today and scale this so that someone can call up a center and within a very short period of time, getting and get treated, then what I think could happen is that person in their desperation to achieve relief is going to go find a dealer down some place and try to do it on the cheap, and there's all kinds of risks associated with that. Our mission is to make sure that, that doesn't happen.

Charles Duncan analyst
#71

Very helpful perspectives. One last question for you, which you probably won't answer. But can you provide any additional color on enrollment progress for Phase III? Or is that something to be discussed in the future?

Kabir Nath executive
#72

Thanks, Charles. We're on track. And welcome to London, and I look forward to seeing you later this week.

Stephen Schultz executive
#73

Thank you, Charles. Appreciate it. The next question comes from Tom Shrader of BTIG.

Thomas Shrader analyst
#74

Relatively new for a lot of us. Can you talk about how the codes will anticipate -- do I have a terrible echo?

Stephen Schultz executive
#75

No, It's fine.

Thomas Shrader analyst
#76

Okay. Can you talk about how the codes will anticipate regional variations in cost and billing, which right now in this field are enormous.? And also, do you expect -- I understand these are early codes. Do you expect the final codes to prescribe a specific treatment paradigm to help enforce the idea that patients need to go to all the sessions?

Kabir Nath executive
#77

So Steve, if I can ask you to start on that, but then I'll also invite our guests if they want to jump in on either part of that. But Steve, if I can ask you to start, please?

Steve Levine executive
#78

Yes. Thanks, Kabir. Good questions. I'll take them in reverse order. With the second part about will the codes, as they evolve, require patients to have all parts of the treatment? So this code, as a reminder, is specific to the administration day. Existing codes will cover preparation and integration sessions. And this code is also not specific to any one program, one compound, one indication. It is flexible enough. There's a lot of granularity in the wording of it, and it's also flexible enough that it can be used across a range of psychological support models that will fit a given program. And so with that, there's nothing about the code itself that, in any way, dictates how its treatment is delivered. As to regional differences in the valuation of the code, the Category III code itself isn't valued, Category I will be. The main way that, that code gets valued and Marketa touched on this a bit earlier, is through a process with CMS that sets that initial valuation that's based upon some surveying of health care providers to understand the work and the resources involved in delivering the therapy. And within CMS, there is an average national price, but there is a lot of variability regionally that's determined by various formula that reflect the economics of smaller regions. And this tends to be reflected also in the commercial landscape with variability and reimbursement across regions. But it's not specific to how a code is worded or anything about the code itself, so much as how payers price that code.

Marketa Wills attendee
#79

Yes. I don't know if I have much to add to that. This is Marketa. Well stated. Again, it just starts with Medicare first, and they typically really look towards the provider to begin to price. And then we, as plans to support either CMS pricing or commercial pricing afterwards or Medicaid. We'll do an actuarial analysis based on that can differ by region.

Geoffrey Grammer attendee
#80

Yes. I don't have much to add to any of those comments. What I would say, I think the second half of that was sort of can the codes help enforce compliance? It's kind of interesting in the world of interventional psychiatry because we're really seeing a remarkably high level of compliance with treatment modalities, and I suspect the same will be within the psychedelic community. If we think about reasons for noncompliance in the treatment resistant space, the #1 reason that we see in studies like Spravato so forth are going to be lack of efficacy and then followed by intolerance, right? And so these are treatments that truly are a progression in the way that we're treating these diseases, and they tend to be well tolerated, efficacious, at least we think we hope and that enhances compliance. So if we look at things like TMS therapy and Spravato, I'll tell you both our only internal data and data from manufactures shows compliance with those modalities is really, really high. And it makes sense, you know, if you have to take a medication every single day for the rest of your life, and it's causing sexual side effects and weight gain, you may not want to do that. And so when you have a true alternative that is better tolerated, more efficacious, particularly in the TRD space, I don't think we're going to have to convince patients to stick with it because in the end, what patients are seeking out is relief for symptoms, and that's going to motivate them more than anything else.

Kabir Nath executive
#81

Thanks very much, Geoff. Marketa, Steve.

Stephen Schultz executive
#82

And the next question comes from Sumant Kulkarni of Canaccord Genuity. Sumant, please go ahead.

Sumant Kulkarni analyst
#83

So given -- clearly it's a major achievement to have a CPT III code so early in this proper. But how closely does the administration of COMP360 in your Phase III program confirmed to the reimbursable aspect of this code? And are there any elements of your future pivotal programs you might need to tweak to be able to most closely align with this code?

Kabir Nath executive
#84

Thanks, Sumant, for that question. And I'll ask Steve to take that, please?

Steve Levine executive
#85

Yes, it's a great question, Sumant. By design, the writing, the language of this code is built to work for programs in our development now, but to be a bit future-proofed against additional compounds or indications in the future because it can be reported in hour at a time. So there is a base number of hours necessarily, at least in its category III form because the description of the support during that administration day covers a range of possible interventions, leading from more passive monitoring through crisis intervention. This is a code that is purpose built to be widely applicable not just to COMP360 for treatment-resistant depression or MAPS's assisted therapy for PTSD with MDMA but a range of possible compounds and other indications that could be explored in the future.

Stephen Schultz executive
#86

And thank you. And with that, we have reached to the top of the hour and the end of our program. Thank you all for joining. I'll hand now the call back to Kabir for final comments.

Kabir Nath executive
#87

Thank you very much, Steve. So first of all, thanks to Dr. Marketa Wills and Dr. Geoffrey Grammer for joining us. Thank you for lending your perspectives on this very important development. Thank you to Steve Levine as well our in-house expert on all this. And thank you to all of you who attended. Apologies again for the slight delay and some of the technical glitches, but we look forward over time to keeping you acquainted with developments in this and really showing you the evidence of how in parallel with pursuing our Phase III program, which is clearly on critical track we are building core elements towards successful commercialization launch and the ability to help patients at scale should COMP360 psilocybin therapy be approved. So thank you, everyone. Have a very good rest of the day, wherever you may be.

Operator operator
#88

This concludes today's conference call. Thank you for your participation. You may now disconnect. Everyone have a wonderful day.

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