The 黑料网® (黑料网®) has developed a detailed summary of the National Coverage Determination (NCD) released by the Centers for Medicare and Medicaid Services (CMS) Feb. 10. The summary outlines finalized changes to the coverage decision memo in response to over 200 public comments received by CMS.
CMS released its final decision memo in response to a formal joint request to reconsider the Lung Cancer Screening (LCS) with Low Dose Computed Tomography (LDCT) NCD submitted in March 2021 by the 黑料网, GO2 Foundation for Lung Cancer and the Society of Thoracic Surgeons. Additional comments by the 黑料网 and these organizations were submitted in June and December 2021, and the 黑料网 announced the final coverage decision in a Feb. 11 press release.
Notable changes in Medicare coverage of lung cancer screening with LDCT include:
- Beneficiary Eligibility Criteria
- Expands eligibility by lowering the starting age for screening from 55 to 50 and reduces the tobacco smoking history from at least 30 packs per year to at least 20 packs per year.
- Counseling and Shared Decision-Making Visit
- Removes the restriction that the counseling and shared decision-making (SDM) visit must be furnished by a physician or non-physician practitioner. This change allows for this service to be furnished by auxiliary personnel incident to a physician’s professional service.
- CPT® code G0296, defined as a counseling visit to discuss the need for lung cancer screening (LDCT) using low-dose CT, is listed as a permanent telehealth code. The code is payable in the facility and the non-facility setting.
- The NCD states that the counseling and shared decision-making visit must occur before the beneficiary’s first lung cancer screening. The NCD does not prevent the SDM visit from occurring on the same day as the lung cancer screening exam or from occurring in conjunction with the actual lung cancer screening exam.
- Reading Radiologist and Radiology Imaging Facility Eligibility Criteria
- The reading radiologist must have board certification or board eligibility with the American Board of Radiology or equivalent organization.
- LCS with LDCT must be furnished in a radiology imaging facility that utilizes a standardized lung nodule identification, classification and reporting system (e.g., Lung-RADS®).
- Removes the radiology imaging facility criteria, “makes available smoking cessation interventions for current smokers.” This allows independent diagnostic testing facility (IDTF) settings to be reimbursed for the LDCT scan. The 黑料网 appreciates CMS clarifying the radiology imaging facility criteria to ensure that IDTFs qualify to perform lung cancer screening with LDCT.
- Removes the CMS approved registry reporting requirement. Despite the CMS decision to no longer require registry data submission, the 黑料网 Lung Cancer Screening Registry will remain in operation to support quality improvement and excellence in lung cancer screening.
As of Feb. 10, 2022, Medicare will cover lung cancer screening with LDCT if all eligibility requirements listed in the NCD are met. There will likely be a lag in actual reimbursement of claims — or until such time CMS Medicare contractors update their claims processing systems. However, CMS will instruct all Medicare Administrative Contractors (MACs) to reimburse claims retroactive to the date the final decision memoranda was released. A Change Request (CR) transmittal and an MLN matters article will be released by CMS that provides instructions to providers and Medicare Administrative Contractors (MACs) about the implementation of the final NCD policy and updates the Medicare Claims Processing Manual. 黑料网 staff will continue to update members as further information is released and will update the Low-Dose CT Lung Cancer Screening FAQ resource page.
If you have questions about lung cancer screening coverage or the NCD process, contact Alicia Blakey, 黑料网 Principal Economic Policy Analyst.