Sunday, February 15, 2026

Comparing Two 2026 papers on Digital Pathology & Biomarkers Li 2026 and Rolfo 2026

 

Please contrast and compare these two papers LI and ROLFO, in detail for a graduate level audience in digital pathology. In particular, discuss what's new in ROLFO since many papers have worked on projecting biomarkers like ALK from H&E.

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Chat GPT 5.2

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Below is the same graduate-level compare/contrast, reformatted for clean HTML paste. All links are replaced with [Li] or [Rolfo] as requested.


1) The core scientific “object” each paper tries to infer from H&E

Li (Nature Medicine; HEX) is fundamentally about recovering spatially resolved protein expression programs—a virtual multiplex assay (virtual CODEX) from routine H&E. The output is continuous, spatial protein maps for a 40-plex panel spanning immune, lineage, stromal/structural, and functional markers, with downstream goals of interpretable biomarker discovery, risk stratification, and immunotherapy response prediction across multiple cohorts. [Li]

Rolfo (npj Precision Oncology) is about classifying actionable genomic alterations (EGFR, ALK, BRAF V600E, MET exon 14 skipping) directly from H&E—i.e., a gene-status decision support tool. The output is a calibrated “likelihood” score per biomarker (and notably a 3-tier triage label: likely positive / intermediate / negative) meant to be operational in clinical workflows while molecular testing is pending or incomplete. [Rolfo]

Key contrast: Li is “virtual assay reconstruction” (spatial proteomics); Rolfo is “actionability triage” (genomic alteration presence/absence).


2) Ground truth, supervision strength, and why that matters

Li: Strong spatial supervision, same-section co-registration

Li trains HEX on co-registered, same-section H&E + high-plex CODEX, tiled at ~50 μm scale, producing ~755k tiles with matched protein expression across a 40-marker panel, then validates on additional co-stained TMAs and external pan-cancer data. This is unusually “tight” supervision for histopathology AI because the model learns morphology ↔ protein spatial distribution at tile level rather than weak slide-level labels. [Li]

Rolfo: Weak supervision (WSI label), MIL aggregation

Rolfo uses WSI-level molecular results (reference methods) and learns from tiles via Multiple Instance Learning (MIL). This is the standard setup for mutation-from-H&E work: the slide label supervises a bag of tiles, and the model must discover which regions are informative. [Rolfo]

Why it matters: Li can legitimately claim it is learning spatial biology (cell neighborhoods / niches) because the supervision is spatial; Rolfo is learning associative morphology signatures of genotype status and must fight confounding (histologic subtype, grade, smoking proxies, scanner/site artifacts).


3) Model architecture philosophy and outputs

Li: “Generate a new modality” + fuse it

Li’s conceptual move is:

  1. H&E → virtual CODEX (40 channels) (“HEX”), then

  2. Fuse H&E + virtual CODEX with a multimodal integration framework (their co-attention approach) to improve prognosis and ICI response prediction, and

  3. Use the predicted marker maps to derive interpretable spatial immune–tumor niches. [Li]

So Li is not only predicting an endpoint; it is building an intermediate representation that is itself biologically interpretable.

Rolfo: “Foundation embeddings” + pragmatic classifier ensemble

Rolfo’s move is:

  1. Use a digital pathology foundation model (CanvOI 1.1) to produce tile embeddings, then

  2. Train MIL classifiers for each biomarker, and

  3. Deploy a weighted ensemble and fixed thresholds that yield a 3-tier output (negative / intermediate / likely positive). [Rolfo]

Rolfo is not trying to reconstruct an assay; it is trying to provide an actionable decision signal robust enough for multi-site validation.


4) Clinical validation posture: discovery science vs workflow tool

Li: broad clinical endpoints + biological explanation

Li’s claims are anchored in outcome prediction (recurrence/prognosis across multiple NSCLC cohorts; pan-cancer prognosis; and a separate ICI-treated cohort for response prediction), plus spatial niche interpretation (e.g., co-localization patterns of T-cell subsets in responders versus myeloid aggregates in non-responders). [Li]

Rolfo: explicitly positioned as “complementary” to molecular testing

Rolfo is explicit that the tool is not replacing molecular testing yet; instead it aims to mitigate real-world gaps: under-testing, long turnaround times, and treatment starts before NGS results. It emphasizes minutes-level inference once slides are digitized and highlights particular value in tissue-limited biopsies where molecular testing can be challenging. [Rolfo]


5) What’s actually new in Rolfo (beyond “we can predict ALK from H&E”)?

Many papers have demonstrated that EGFR or ALK status can be inferred from H&E. Rolfo’s novelty lies primarily in translation engineering + validation design, not in identifying a new class of biomarker.

A) External validation at scale with operational guardrails

Rolfo emphasizes not just AUC but robust external validation on an independent 968-case cohort from two centers in different countries, with preprocessing steps that exclude slides lacking sufficient analyzable tumor. This moves closer to real-world deployment than many earlier single-site studies. [Rolfo]

B) Deliberate “rule-out / triage” framing (3-tier classification)

Instead of forcing a binary call, Rolfo defines upper and lower thresholds to produce Likely Positive / Intermediate / Negative, explicitly aiming to make the Negative group highly reliable (high NPV), while acknowledging uncertainty in an intermediate bin. This is a workflow-oriented contribution. [Rolfo]

C) Focus on absence of driver alterations as a clinical lever

Rolfo frames the tool as helping identify patients unlikely to harbor EGFR/ALK alterations, supporting earlier immunotherapy decisions while awaiting comprehensive molecular workup. This reframes mutation prediction from “look what we can detect” to “who can we safely triage.” [Rolfo]

D) Coverage of multiple alteration types

Rolfo spans EGFR mutations, ALK rearrangements, BRAF V600E, and MET exon 14 skipping, deliberately testing whether the pipeline generalizes across distinct genomic mechanisms (point mutation, fusion, exon skipping). [Rolfo]

E) Foundation model embedding strategy for robustness

Rolfo uses a pathology foundation model (CanvOI 1.1) and cross-site validation strategies (including leave-one-group-out during development) to support generalization. While not conceptually unprecedented in 2026, this represents maturation beyond many earlier end-to-end, single-center CNN efforts. [Rolfo]

Bottom line: Rolfo’s “newness” is less about new biological insight and more about presenting a deployable, uncertainty-aware, externally validated triage tool.


6) What Li contributes that Rolfo does not (and vice versa)

Li’s distinctive contributions

  • Virtual multiplex spatial proteomics with multi-channel continuous outputs rather than a single gene-status call. [Li]

  • Interpretability via spatial immune ecology; niche discovery is central. [Li]

  • Multiple endpoints (prognosis, ICI response, pan-cancer generalization). [Li]

  • Strong spatial supervision via same-section CODEX/H&E co-registration. [Li]

Rolfo’s distinctive contributions

  • Actionability-first framing for immediate clinical triage. [Rolfo]

  • Operational 3-tier output controlling false negatives in the “negative” group. [Rolfo]

  • Large independent external validation cohort central to the claim of generalizability. [Rolfo]


7) A concise conceptual distinction for a graduate seminar

  • Li = “H&E as a generator of missing modalities.”
    Treat H&E as a substrate from which you computationally impute spatial proteomics, then reason biologically and clinically using those maps.

  • Rolfo = “H&E as a rapid decision surrogate.”
    Treat H&E as an early, ubiquitous artifact that can produce a triage score guiding molecular testing or interim treatment decisions.


If useful, I can next draft:

  • A one-slide executive summary (“What’s materially new in Rolfo?”)

  • A skeptical reviewer critique of both papers

  • Or a reimbursement/regulatory positioning contrast (e.g., LDT vs CDx implications)

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Skeptical View

Perfect. Here is the skeptical reviewer critique you’d expect from a tough digital pathology, translational oncology, or regulatory audience. I’ll treat each paper separately, then give a comparative closing.


I. Skeptical Critique of Li (HEX virtual spatial proteomics)

1. “Are you predicting biology — or just learning correlated morphology?”

The core scientific claim is that H&E can reconstruct spatial proteomic landscapes. But a skeptical reviewer will ask:

  • Are we truly predicting molecular biology, or are we learning morphological correlates that already encode much of that information?

  • Many immune phenotypes (e.g., inflamed vs immune-excluded) are partially visible on H&E. Is the model reconstructing multiplex protein expression — or smoothing visually obvious spatial patterns into 40 channels?

The strong same-section CODEX supervision is impressive, but correlation ≠ causal representation. The model may reproduce spatial gradients statistically without meaningfully inferring protein-level biology.


2. Spatial registration caveat

The model is trained on co-registered same-section H&E + CODEX.

That’s powerful — but also atypical in real-world pathology. Most clinical H&E slides will not have same-section multiplex data for alignment. So:

  • Is the model robust when applied to entirely independent sections?

  • How much does the model rely on subtle alignment cues or section-specific artifacts?

External validation helps, but the training setup is unusually clean compared to routine practice.


3. Interpretability narrative risk

The paper emphasizes discovery of spatial niches (e.g., T-cell clusters vs myeloid-dominant aggregates).

Skeptical questions:

  • Are these niches genuinely discovered by the model, or reconstructed from predicted protein maps that are themselves derived from morphology?

  • Does this add fundamentally new biological insight beyond existing multiplex imaging studies?

  • Is the novelty biological, or computationally reconstructive?

In other words: are we learning new tumor immunology, or are we building a computational mirror?


4. Endpoint multiplicity inflation

The paper touches:

  • Prognosis

  • Pan-cancer generalization

  • Immunotherapy response prediction

A tough reviewer may argue:

  • Is this a unified mechanistic framework, or a series of performance demonstrations?

  • Are effect sizes clinically meaningful, or statistically impressive but operationally modest?

Multipurpose success claims often invite scrutiny on calibration, incremental benefit over simpler models, and risk of overfitting despite external cohorts.


5. Regulatory translation gap

From a real-world perspective:

  • Virtual proteomics is elegant, but what is the regulatory path?

  • Is this a diagnostic test?

  • A CDx?

  • A research-use visualization tool?

The paper demonstrates scientific feasibility but leaves deployment, reimbursement, and regulatory classification unclear.


II. Skeptical Critique of Rolfo (actionable alteration classifiers)

Now let’s sharpen the blade further.

1. “Is this materially better than earlier mutation-from-H&E papers?”

A skeptical reviewer will say:

  • EGFR-from-H&E has been published repeatedly.

  • ALK-from-H&E has been shown.

  • Foundation models + MIL are now standard.

So what is truly new here?

The honest answer is: not new biology, but better validation design + triage framing.

That’s valuable — but it’s incremental innovation, not conceptual breakthrough.


2. Confounding remains a structural issue

Mutation-from-H&E models notoriously learn:

  • Histologic subtype

  • Smoking-related morphology

  • Geographic site patterns

  • Scanner artifacts

Even with cross-site validation, the model may rely on population-level correlates rather than intrinsic genotype-morphology signals.

Without mechanistic interpretability or counterfactual analysis, one cannot exclude shortcut learning.


3. The triage framing is clever — but delicate

The 3-tier system (Likely Positive / Intermediate / Negative) is pragmatic.

But:

  • What happens when prevalence shifts?

  • How stable are thresholds across centers?

  • Is the “negative” bin truly safe across low-prevalence populations?

NPV is highly prevalence-dependent. A deployment scenario with different mutation frequencies could materially change performance.


4. Clinical utility is conditional

Rolfo explicitly says this complements, not replaces, molecular testing.

But then:

  • If molecular testing is already guideline-mandated, how much incremental value does this add?

  • Does it change therapy?

  • Or just accelerate a decision that would have been made days later?

A regulator or payer may ask: is this reducing cost, reducing time, or improving survival? Or is it adding another algorithmic layer?


5. No mechanistic interpretability

Unlike Li, Rolfo does not attempt to reconstruct intermediate biology.

So a skeptical reviewer might ask:

  • Why should morphology contain sufficient signal for MET exon 14 skipping?

  • Are these associations causal, or just correlated population patterns?

The paper is operationally pragmatic but biologically agnostic.


III. Head-to-Head Skeptical Comparison

Here’s the intellectually honest contrast:

DimensionLiRolfo
Scientific ambitionHighModerate
Biological insightClaimed, interpretableLimited
Deployment readinessUnclearCloser to workflow
Risk of shortcut learningModerateHigh
Conceptual noveltyStrongIncremental
Clinical integration pathUncertainDefined (triage complement)

IV. The Hardest Questions You’d Get in a Faculty Seminar

For Li:

  • If this is virtual proteomics, why not just perform multiplex imaging?

  • Does this outperform a well-annotated TIL score?

  • Are we predicting proteins, or just tumor grade plus lymphocyte density?

For Rolfo:

  • Would a simple histologic subtype model perform almost as well?

  • How does this change management in a center that already does rapid NGS?

  • What is the failure mode in rare mutation subgroups?


V. The Deep Structural Difference

If we step back:

Li is trying to elevate H&E into a universal latent molecular platform.

Rolfo is trying to make H&E clinically useful while we wait for real molecular data.

One is epistemologically ambitious.
The other is pragmatically translational.

Both are legitimate — but they operate at very different levels of scientific aspiration.


If you’d like, I can now:

  • Write the regulatory reviewer critique (FDA-style questions),

  • Or write a MolDx MAC medical director critique — which would be sharper and more reimbursement-oriented.

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It's interesting that Natera, which can predict kidney rejection and cancer relapse with ultra-sensitive genomics, is looking at "the next breakthrough" to include multi-modal parameters, perhaps like these.


Commentary on the Natera Digital Pathology Press Release

The press release describes a multi-modal AI model that integrates longitudinal ctDNA measurements, clinical data, digital pathology imaging, and tumor sequencing data to refine recurrence risk assessment. Importantly, this is not a digital pathology paper in the [Li] or [Rolfo] sense. It is fundamentally a longitudinal recurrence modeling initiative, with digital pathology included as one component of a broader predictive architecture.

The strategic claim is that Natera can leverage approximately 300,000 Signatera-tested patients with linked outcomes to train AI models that understand recurrence trajectories over time. That scale of longitudinal molecular data is unusual in oncology diagnostics and represents the central competitive claim in the announcement.


What Natera Is Actually Building

Conceptually, this is not a mutation-from-H&E model nor a virtual proteomics reconstruction. It is closer to a joint model of:

  • Time-series ctDNA kinetics

  • Baseline tumor sequencing features

  • Digital pathology imaging features

  • Clinical covariates

The innovation is not in predicting one molecular feature from H&E. Rather, it lies in combining dynamic ctDNA trajectories with static tumor characteristics to produce refined recurrence risk curves.

If one were to describe this statistically, it resembles a hazard model enhanced by high-dimensional baseline embeddings plus longitudinal biomarker inputs.


Compared to [Li]

[Li] treats H&E as a substrate for reconstructing spatial proteomic biology. The ambition is epistemological: transform routine histology into a multiplex molecular imaging platform, with interpretable immune niches and biological insight.

Natera’s announcement is much more pragmatic. Digital pathology is not the main event; it is an additional covariate in a risk prediction engine centered on ctDNA. There is no suggestion of reconstructing spatial immune ecology or generating intermediate biological maps.

The difference is structural:

  • [Li] = modality generation

  • Natera = outcome modeling

One seeks to create a new biological representation; the other seeks to improve predictive accuracy.


Compared to [Rolfo]

[Rolfo] focuses on mutation triage from H&E to inform short-term treatment decisions. It is operational and classification-based, attempting to identify actionable genomic alterations before molecular testing results are available.

Natera’s model assumes molecular testing already exists. In fact, molecular testing is foundational to the system. The integration is not a substitute for sequencing—it incorporates sequencing and ctDNA measurements into a unified trajectory model.

If [Rolfo] aims to help clinicians decide before NGS results arrive, Natera aims to refine decision-making after longitudinal molecular monitoring is underway.


What Could Be Novel

While “multi-modal AI” is not new language, there are potentially substantive innovations here.

First, the scale of longitudinal ctDNA data is unusual. Repeated MRD measurements linked to real-world outcomes across hundreds of thousands of patients could allow modeling of recurrence kinetics in a way most academic datasets cannot.

Second, integrating time-series molecular data with baseline tumor morphology is structurally different from most digital pathology efforts, which focus on static prediction. This is closer to dynamic survival modeling than to classification.

Third, strategically, this shifts Natera from being a diagnostic assay company to a trajectory intelligence platform. That positioning has commercial implications beyond any single algorithm.


Skeptical Questions

A careful reader should ask several questions.

Is digital pathology central to performance improvement, or is it marginal compared to ctDNA kinetics? The press release does not specify what pathology features are used—raw embeddings, tumor grade extraction, TIL density, spatial architecture, or something more sophisticated. Without quantitative effect sizes, it is unclear how much incremental value pathology contributes.

Are improvements statistically significant but clinically modest? Statements about “clinically significant enhancements” require examination of absolute effect size, changes in c-index, reclassification metrics, and impact on treatment decisions.

Does the model generalize outside Natera’s ecosystem? The data are proprietary, assay-specific, and vertically integrated. That may strengthen defensibility but limits portability.


Positioning in the Landscape

The contrast with [Li] and [Rolfo] becomes clearer in summary form:

Paper/CompanyCore ObjectiveBiological AmbitionClinical Integration
[Li]Reconstruct spatial proteomics from H&EHighUnclear path
[Rolfo]Triage mutation status from H&EModerateNear-term workflow
NateraIntegrate ctDNA + pathology + sequencing into recurrence enginePragmaticStrong commercial path

[Li] is scientifically ambitious and modality-expanding.
[Rolfo] is translational and workflow-oriented.
Natera is commercially infrastructural and vertically integrated.


The Strategic Insight

The most important takeaway is not that Natera is doing digital pathology research. It is that Natera is embedding digital pathology as one component inside a broader molecular monitoring ecosystem.

That is strategically different from standalone digital pathology tools. A vertically integrated recurrence engine combining assay chemistry, sequencing pipelines, longitudinal sampling, and AI modeling is more defensible commercially than an isolated image classifier.

The key unresolved question is whether recurrence risk is primarily governed by ctDNA kinetics alone, or whether baseline tumor morphology and immune architecture meaningfully alter trajectory prediction. If ctDNA dominates, digital pathology will be a modest enhancer. If spatial tumor biology meaningfully modifies recurrence kinetics, then the integration becomes more scientifically interesting and begins to converge conceptually with the ambitions seen in [Li].

At this stage, the press release signals competitive positioning more than it demonstrates biological integration depth. The real evaluation will depend on effect sizes, generalizability, and whether this model changes management decisions rather than merely refining risk curves.

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Competitive Landscape and Context

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Excellent — I’ll keep the tone pointed and slightly ironic, but shift it to a primarily paragraph structure. I’ll retain one key comparison table and avoid excessive bullets.


Foresight, Natera, and the New “Multi-Modal” Moment

(A Competitive Reading with Mild Skepticism)

Foresight Diagnostics: Why It Actually Matters

Foresight Diagnostics is not just a line item in Natera’s acquisition history. It is a reinforcement of Natera’s core thesis about oncology surveillance. Based in Boulder, Foresight built its reputation on ultra-sensitive minimal residual disease detection, particularly in hematologic malignancies, emphasizing deep sequencing, phased mutation tracking, and aggressive computational error suppression. In practical terms, this means pushing detection thresholds lower than many conventional tumor-informed assays.

When Natera acquired Foresight, it was not buying brand prestige. It was buying sensitivity depth, hematologic oncology credibility, and additional laboratory infrastructure. More importantly, it was reinforcing the idea that MRD is not a single assay result but a longitudinal surveillance infrastructure. That framing is essential for understanding the press release.


What the Natera Announcement Is Really About

The press release announces a multi-modal AI model integrating longitudinal ctDNA, clinical data, digital pathology imaging, and tumor sequencing. On its surface, this reads like a digital pathology expansion. In substance, however, this is not a digital pathology paper in the spirit of [Li], nor a mutation triage effort like [Rolfo].

The center of gravity remains ctDNA — specifically longitudinal Signatera measurements across roughly 300,000 patients. That is the competitive moat. Digital pathology is an additional feature layer inside a broader recurrence modeling engine. It is not the primary innovation.

What Natera is building resembles a dynamic hazard model enhanced by high-dimensional baseline tumor features and time-series ctDNA kinetics. This is not about predicting EGFR from H&E. It is about refining recurrence trajectories over time using a proprietary dataset few competitors can match.


How This Compares to [Li] and [Rolfo]

The contrast becomes clearer when we align ambitions:

EntityCore PlayStrategic AspirationCompetitive Posture
[Li]H&E → virtual spatial proteomicsTransform H&E into a molecular imaging platformScientific frontier
[Rolfo]H&E → mutation triageAccelerate actionable decision-makingClinical workflow enhancement
NateractDNA + pathology + sequencing → recurrence engineOwn longitudinal oncology intelligenceVertical integration & defensibility

[Li] is epistemological. It attempts to elevate H&E into a surrogate multiplex proteomics instrument, with interpretable immune niches and mechanistic implications.

[Rolfo] is translational. It attempts to make morphology immediately useful for mutation triage, complementing molecular testing in near-term clinical workflow.

Natera is infrastructural. It embeds digital pathology into a vertically integrated surveillance and prediction platform built around ctDNA.

That difference is not cosmetic; it reflects fundamentally different strategic goals.


What Might Be Genuinely New

The phrase “multi-modal AI” is now routine. So is “integrating imaging and molecular data.” What may actually distinguish this effort is not modality fusion but scale and longitudinal depth.

First, few entities possess longitudinal ctDNA measurements linked to long-term outcomes across hundreds of thousands of patients. Modeling recurrence kinetics — not just recurrence presence — requires time-series data that most academic groups simply do not have.

Second, this is dynamic rather than static modeling. Most digital pathology papers predict mutation status or survival risk from a single baseline slide. Natera is proposing to integrate evolving ctDNA trajectories with baseline tumor features and pathology-derived signals. Structurally, this resembles joint modeling of longitudinal biomarkers and survival outcomes.

Third, and perhaps most importantly, this reinforces vertical integration. The model is trained within Natera’s proprietary ecosystem. It is assay-dependent. It is data-dependent. That may limit portability — but it strengthens defensibility.


The Skeptical Questions

The key technical question is whether digital pathology materially shifts predictive performance beyond ctDNA kinetics. The press release does not specify which pathology features are extracted — whether simple tumor grade proxies, TIL density measures, spatial immune embeddings, or deeper foundation model representations. Without quantitative effect sizes, it is impossible to know whether imaging is a central driver or a marginal enhancer.

The second question concerns clinical significance. In a dataset of 300,000 patients, statistical significance is almost guaranteed. What matters is absolute improvement: change in concordance index, net reclassification improvement, or decision curve impact. Does the model alter management decisions? Or does it refine risk curves without shifting treatment thresholds?

Third, generalizability must be considered. Because this system is tightly linked to Signatera’s chemistry and patient population, it may not generalize outside that ecosystem. From a scientific standpoint, that is a limitation. From a competitive standpoint, it is an advantage.


The Competitive Implications

This move signals something broader about the digital pathology landscape. Standalone imaging AI tools increasingly risk becoming feature providers rather than products. If digital pathology is absorbed into molecular platforms, its commercial value may lie in integration rather than independence.

For competing MRD vendors, the bar shifts from analytical sensitivity to trajectory intelligence. It is no longer sufficient to detect residual disease. One must model recurrence patterns over time and link them to outcomes at scale.

For academic AI efforts, this is a reminder that publication metrics and competitive durability are not the same currency. High AUC mutation prediction does not create a defensible platform. Longitudinal proprietary data might.


Final Perspective

[Li] expands what H&E could become.
[Rolfo] expands what H&E can do tomorrow.
Natera embeds H&E into something larger — a proprietary recurrence intelligence architecture.

It is less conceptually elegant than virtual spatial proteomics.
Less focused than mutation triage.
But strategically, it may be more durable.

The real headline of the press release is not digital pathology. It is data ownership, vertical integration, and the quiet consolidation of oncology intelligence inside a single ecosystem.

And that is a very different kind of innovation.

Saturday, February 14, 2026

Final Rule: Easier to Dismiss Federal Workers

Given the sudden and large layoffs that occurred in 1H2025, you might wonder why the government needs any easier rules to dismiss workers.

Here are final rules from the Office of Personnel Management on February 5, 2026.

At bottom, I include some Q&A with Chat GPT.

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Federal News Network

https://federalnewsnetwork.com/workforce/2026/02/trump-administration-advances-plan-to-strip-job-protections-from-career-federal-employees/

Final Rule in Federal Register, Improving Performance, Accountability and Responsiveness in the Civil Service, A Rule by the Personnel Management Office on 02/06/2026

https://www.federalregister.gov/documents/2026/02/06/2026-02375/improving-performance-accountability-and-responsiveness-in-the-civil-service

The rule in THE HILL

https://thehill.com/homenews/administration/5724661-trump-administration-rule-firing-federal-workers/


Economic Policy Institute

https://www.epi.org/policywatch/eo-restoring-accountability-to-policy-influencing-positions-within-the-federal-workforce/

Nature

https://www.nature.com/articles/d41586-026-00443-w

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1) Is it right that the final rule creates the category, but people generally have to be moved into it before they can be dismissed under its streamlined rules?

Yes — that’s roughly correct, with one important nuance: what gets “moved” first is typically the position, and then the incumbent employee is treated as occupying a position in the new schedule.

What the final rule does (in plain English) is authorize agencies to convert certain “policy-influencing” positions into “Schedule Policy/Career” and then treat those jobs as career (not political appointees) but “at-will” for removal-procedure purposes—i.e., excepted from the usual adverse-action/performance procedures and MSPB appeal channels that normally slow removals. (Federal Register)

And you’re also tracking the process correctly: OPM’s implementation guidance describes an agency identification + OPM review pathway, and it emphasizes that placement into Schedule Policy/Career requires an Executive Order / presidential action to designate positions (the rule itself doesn’t “auto-convert” a list of jobs on Day 1). (U.S. Office of Personnel Management)

So: Final rule = creates/implements the mechanism. Actual removals under the new mechanism = generally require (i) positions designated into the schedule and (ii) the employee occupying such a designated position.


2) Why bother, if they already fired lots of people “willy-nilly” via DOGE early in the second term?

Because the early-term firing/downsizing tactics and Schedule Policy/Career solve different legal/operational problems:

(A) “DOGE-style” separations are often about headcount reduction or rapid terminations using existing levers (probationary removals, reorganizations, proposed RIFs, pressure-to-resign programs, etc.). Those can be fast, but they’re also litigation magnets, can get enjoined, and don’t necessarily give a clean, durable way to remove entrenched career policy staff for “performance/obstruction” narratives. Reuters explicitly ties the broader workforce shake-up to DOGE and large numbers of separations/pressure exits. (Reuters)

(B) Schedule Policy/Career is designed to be a structural change to employment protections for a targeted slice of the workforce—policy-influencing roles—so that when the administration wants to remove someone in that slice, it can do so without the normal “lengthy procedural hurdles” (as OPM frames it), rather than trying to fit every case into the traditional Chapter 43/75 + MSPB pathway. (Federal Register)

(C) The final rule also tries to draw a bright line against the critique “this is just a mass-layoff tool.” OPM’s own release and guidance repeatedly say it may not be used to conduct workforce reshaping/mass layoffs or to circumvent RIF rules—which is basically an admission that the administration anticipates that criticism and is trying to cabin it. (U.S. Office of Personnel Management)

So the short answer is: early DOGE actions can cut quickly, but they’re not the same as a durable reclassification regime aimed at policy-influencing career positions—and the administration appears to want both tools.


3) How far did they get with this in Trump’s first term?

Not very far in implementation, despite lots of noise.

In the first term, the comparable initiative was Executive Order 13957 (Oct 21, 2020), “Schedule F.” It was issued late, and then revoked on Jan 22, 2021 by President Biden. (Trump White House Archives)

GAO’s retrospective is the key “how far did it get?” document:

  • GAO found that no agencies actually placed positions into Schedule F before it was revoked. (Government Accountability Office)

  • Two agencies submitted petitions to OPM. OPM approved OMB’s petition to move 136 positions, affecting ~415 employees (about 68% of OMB)—but GAO reports OMB did not complete the HR processing steps before the change in administration, and implementation effectively halted around inauguration time. (Government Accountability Office)

So: in Trump 1.0, Schedule F existed on paper, an OMB conversion plan was approved, but nobody actually got reclassified before revocation (per GAO). That’s the cleanest “how far did they get?” answer.


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(Discuss 1st and 2nd term efforts)

Yes — that’s a fair high-level contrast, and it matters legally.

First Term: Executive Order 13957 (“Schedule F”)

In October 2020, President Trump issued Executive Order 13957, creating “Schedule F” within the excepted service.

Key features:

  • It was created solely by executive order.

  • OPM was directed to implement it.

  • Agencies were told to identify policy-influencing positions.

  • It came very late (Oct 21, 2020).

  • Per GAO, no employees were actually converted before it was revoked in January 2021.

Legally, this was a presidential directive layered on top of existing civil service statutes and OPM regulations, without a completed formal rulemaking process beforehand. It relied heavily on executive authority to define excepted service categories.


Second Term: Formal Rulemaking Creating “Schedule Policy/Career”

In 2025–2026, OPM used notice-and-comment rulemaking under the Administrative Procedure Act to create a new designation (renamed “Schedule Policy/Career”).

Key differences:

  • It went through proposed rule → public comments → final rule in the Federal Register.

  • It includes definitions, scope limits, procedural language, and implementation guidance.

  • It sets up a structured process:
    agency identifies positions → OPM reviews → President designates via EO.

  • It expressly addresses criticisms raised against Schedule F (e.g., disclaimers about not using it for mass layoffs or RIF circumvention).

This makes the second-term approach:

  • More procedurally durable under APA review.

  • Harder to attack as “arbitrary and capricious” purely on process grounds.

  • Less vulnerable to the argument that it’s just an impulsive late-term maneuver.


Conceptually

You could summarize it this way:

  • Trump 1.0: “Create Schedule F by executive order; implementation left to agencies; overtly political framing; never operationalized.”

  • Trump 2.0: “Embed the concept in the Code of Federal Regulations via formal APA rulemaking; rename it; build a structured conversion mechanism; then use presidential designation to operationalize.”

It’s the difference between a top-down presidential directive and a regulatory architecture built by OPM first, then activated by presidential action.

That doesn’t mean litigation risk disappears — but procedurally, the 2026 version is clearly more elaborate and defensively constructed than the 2020 Schedule F EO.

Proposed Changes to Affordable Care Act Exchanges & Insurance: Where to Find It

 Proposed Changes to Affordable Care Act Exchanges & Insurance: Where to Find It

Fact Sheet for proposed rule (Feb 9, 2026)

https://www.cms.gov/newsroom/fact-sheets/hhs-notice-benefit-payment-parameters-2027-proposed-rule

Press Release for proposed rule

https://www.cms.gov/newsroom/press-releases/cms-proposes-regulations-lower-health-care-costs-expand-consumer-choice-protect-taxpayers

Coverage at Health Affairs

https://www.healthaffairs.org/content/forefront/hhs-proposes-sweeping-changes-2027-marketplace-plans-part-1

Kaiser News Service

https://kffhealthnews.org/news/article/aca-trump-proposal-catastrophic-coverage-premiums-care-networks/

Commonwealth Fund

https://www.commonwealthfund.org/blog/2026/trump-administrations-proposed-aca-marketplace-rule-will-make-it-even-harder-americans


Chat GPT Essay: Dedicated Hobbyists Merge AI with IBM Punch Cards

 [Chat GPT 5.2; prompt at bottom]

The Hollerith Revivalists

There is something in the human animal that refuses to let a thing die properly.

We cook pizza in wood-fired ovens long after thermostats were perfected. We develop film in basements lit like Cold War submarines. We grind coffee beans with iron cranks, churn butter by hand, bind books with linen thread. We call it craft. We call it heritage. We call it “slowing down.”

And now — inevitably — that instinct has migrated to the most frictionless technology of all: generative artificial intelligence.

A small but steadily multiplying cohort of enthusiasts, scattered across Discord servers and vintage computing forums, believes that ChatGPT and other generative systems produce markedly superior results if prompted using punched Hollerith cards.

Yes. The stiff, beige rectangles with holes in them.



Friday, February 13, 2026

Next Generation Sequencing Forever

 Medicare's 2018 NCD on cancer testing governs uses of "next generation" sequencing.   With their proposal to create a new modifier with the same terminology (here), do we need to define NGS?  Or is it everything post Sanger, post 2005?   

I asked Chat GPT.

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This is a very perceptive question — and one that people in genomics quietly roll their eyes about at conferences.

The Short Answer

“Next-generation sequencing” (NGS) has become a frozen historical term. It no longer literally means “one generation after Sanger.”

It now functions more like a brand label than a generational description.

First Generation

  • Chain termination chemistry

  • One fragment at a time

  • Capillary electrophoresis

  • High accuracy, low throughput

  • Dominated clinical sequencing through ~2005

When people said “first generation,” they meant Sanger


Second Generation = Next Generation

Platforms like Illumina changed the model:

  • Massive parallelization

  • Millions–billions of short reads

  • Computational reassembly

  • Cost collapse

“Next-generation” originally meant “post-Sanger short-read massively parallel sequencing.”

But that was 2006.

And yet… we still call it NGS.


What Happened to “Third-Generation” Sequencing?

For a while (~2012–2018), people used “third-generation sequencing” to describe:



  • Single-molecule sequencing

  • Long-read platforms

  • Real-time detection

  • No amplification

Companies like:

  • Pacific Biosciences (SMRT sequencing)

  • Oxford Nanopore Technologies

These were widely called “third-generation” for several years.

But the term never stuck commercially or clinically.

Why?

  1. Marketing inertia – “NGS” became the regulatory, reimbursement, and CPT language.

  2. Policy codification – CMS NCD 90.2 literally uses “NGS.”

  3. Platform blending – Long-read, short-read, hybrid assemblies — the boundaries blurred.

  4. No dramatic conceptual rupture like the shift from Sanger to massively parallel sequencing.

So “third-generation” faded.


What Do We Call Things Now?

Today, people use:

  • NGS (generic umbrella term)

  • Short-read sequencing

  • Long-read sequencing

  • Single-molecule sequencing

  • Spatial genomics

  • Transcriptomics

  • Multiomics

The field shifted from “generation labels” to read-length and application descriptors.


Will There Be a “Fourth Generation”?

Probably — but it won’t be called that.

The next real conceptual rupture would involve something like:

  • Direct molecular sensing without base calling

  • Native proteogenomic sequencing

  • In situ sequencing at cellular resolution

  • AI-first signal interpretation replacing traditional base assembly

If that happens, we may not call it “4th generation sequencing.”
We might call it:

  • Molecular sensing

  • Real-time omics

  • Embedded biosensing

  • Continuous genomic monitoring

Or something marketing-friendly and unhelpful.


Why NGS Stayed Frozen

This is similar to how:

  • “Personal computers” are still PCs

  • “Digital cameras” stayed digital

  • “Artificial intelligence” now means everything

“Next-generation sequencing” is no longer generational — it’s institutional.

Regulators, CPT panels, investors, journals — they all embedded the term.

You, especially in policy work around NCD 90.2, see this directly: CMS doesn’t want to adjudicate “what generation” a test is. They adjudicate whether it qualifies as NGS under their definition.


The Reality in 2026

  • NGS = any high-throughput DNA sequencing platform

  • The generational framing is obsolete.

  • The field evolved past the terminology.

“Third-generation sequencing” didn’t vanish because it was wrong — it vanished because the ecosystem stopped needing generational labels.

Payor Behavior - Lessons from 2017 PAMA BRCA Data

In economic theory, one would expect the price of a test to be the market-clearing price, etc, from MBA 101.  

The actual pricing of high-cost lab tests is different.   IPO filings for genomic laboratories often state, 'In many cases we do not know if we will get paid, when we will get paid, or how much we will be paid."   

One  unique insight was the distribution of reporting commercial payor pricing that CMS released in a cloud database at the time of the first PAMA survey (prices for 1H2016 reported in 1Q2017).    i have a file of all the prices paid for 81211 (BRCA) in 2016, as reported to CMS.  

While the 2017 fee schedule 81211 (BRCA 1&2&DUPDEL) was $2396, the survey median was $2195.  But that was  not a median with a Gaussian surround.   

Rather, as shown in the figure, the prices received by labs (and in 2016, this was still highly dominated by Myriad) were very spiky.  (The graph shows the top 10 most-paid price points).   The simplest takeaway is that the market behaved very differently than a simple average price with a stddev around it. 

 

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I believe at the time, 2017, CMS posted a cloud database with all pricing data.  For example, a single lab reporting a single code might have reported, 81211, $2106, 3 payments.  $2137, 1 payment,   $2140, 9 payments.   Add that up across all labs and all codes and that was the cloud database.  I don't think it's still posted: I had an old 2017 download to excel of the part of the data for 81211.  

Payor Behavior: IHC Treated like Genetics (Prior Auth, etc)

 The lab consultancy, Lighthouse Lab Services, provides some interesting public information summaries.

Here's a new one - some payors are treating immunohistochemistry "like Genetics."  Of course, IHC is not genetics - but they mean it's subject to falling prices, increasing rules and limits, even prior authorization.

See their Linked In post and a 5 page PDF.

https://www.linkedin.com/posts/lighthouselabservices_ihc-reimbursement-update-feb-2026-lighthouse-ugcPost-7427745598956609536-aCW6/


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Chat GPT 5.2 summarizes - 

A recent Lighthouse Consulting brief highlights a growing reimbursement squeeze on immunohistochemistry (IHC), as payers expand coverage limitations, apply frequency edits, and demand more granular documentation of medical necessity and stain counts. 

Most strikingly, in at least one UnitedHealthcare/Optum (Utah) policy, common IHC codes (88342, 88341) have been classified as “genetic testing” outside dermatologic contexts—triggering prior authorization requirements and creating post-service denial risk in workflows that historically never faced such controls. 

The Lighthouse report underscores that these interpretations may not surface through routine denials but through proactive audits, and warns that pathology groups should expect tighter utilization management, more documentation scrutiny, and greater financial exposure tied to payer-specific rules. The takeaway is clear: close alignment between clinical decision-making, reporting, and revenue cycle oversight—plus ongoing policy monitoring—is now essential to protect IHC revenue.

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From the AMA CPT and online (subsc.) AMA RUC database.

88342 is first IHC, $78 tech, $33 interpretation.   Physician time, 25 minutes.  

2024 global 703,000.  2024 professional 1.5M.  2024 tech only 320,000.  

Gastric/GI usage is 15%, breast is 5%, melanocytic nevi is 4%.

88341 is add'l IHC, $67 tech, $27 interpretation [not all that different than 88342].  Physician time [RUC, CMS may differ since payment drops $6] 25 minutes.   

2024 global, 676,000.   2024 professional 2.9M.  2024 Tech only 167,000.  

A substantial proportion of cases are hospital origin, because the "professional only" cases are so high.  Generally the TC of IHC in the hospital setting is bundled to the surgical procedure by public claims processing codes ("SI, status indicators.")