The American College of Radiology recently released a detailed summary of the National Coverage Determination related to screening for lung cancer with low dose computed tomography.
ACR's summary outlines finalized changes in response to more than 200 public comments received by the Centers for Medicare & Medicaid Services. CMS released its final decision following a formal joint request, submitted in March 2021 by the ACR, GO2 Foundation for Lung Cancer, and the Society of Thoracic Surgeons. Additional comments by the ACR and these organizations were submitted in June and December 2021, and CMS announced the final coverage decision Feb. 10.
The agency said its decision expands coverage for lung cancer screening with changes that make it easier for imaging centers to participate and includes younger patients under the new rules.
“Expanding coverage broadens access for lung cancer screening to at-risk populations,” CMS Chief Medical Officer and Director of the Center for Clinical Standards and Quality Lee Fleisher, MD, said in a statement about the changes. “The decision not only expands access to quality care but is also critical to improving health outcomes for people by helping to detect lung cancer earlier. With CMS updating its eligibility criteria, we are certain more people will be able to obtain access to screening."
Several changes in Medicare coverage of CT lung cancer screening in 2022
The three big changes include:
• Beneficiary eligibility criteria: This 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 visit must be furnished by a physician or nonphysician practitioner. This change allows for this service to be furnished by auxiliary personnel incident to a physician’s professional service.
CPT code G0296 is defined as a counseling visit to discuss the need for LDCT, and is listed as a permanent telehealth code, payable in the facility and the nonfacility setting.
The coverage determination states that the counseling and shared decision-making visit must occur before the beneficiary’s first lung cancer screening. It does not prevent the shared decision-making 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 an equivalent organization. Screening with LDCT must also be furnished in a radiology imaging facility that utilizes a standardized lung nodule identification, classification and reporting system (such as Lung-RADS).
The new rule also removes the radiology imaging facility criteria that requires them to make available smoking cessation interventions for current smokers. This allows independent diagnostic testing facility settings to be reimbursed for the CT scan. The ACR said it appreciates CMS clarifying the radiology imaging facility criteria to ensure that such facilities qualify to perform lung cancer screening.
The new rule also removes the CMS-approved registry reporting requirement. Despite the CMS decision to no longer require registry data submission, the ACR Lung Cancer Screening Registry will remain in operation to support quality improvement and excellence in lung cancer screening.
"The screening population is the most important eligibility criteria within the changes," explained Alicia Blakey, American College of Radiology (ACR) principal economic policy analyst. "It is now recommended that patients younger than age 55 can get screened by Medicare. We've gotten several questions from membership on exactly how many patients fall within that category. When we think of Medicare, we think of age 65 and older, and there is actually a growing millions of Americans who could benefit from this screening update due to disability status, as well as if they are in stage renal cancer patients."
She said another notable change from the 2015 recommendations was expanded authorization of these screenings by personal other than physicians, including nurses.
"The nurse coordinator or nurse navigator roles are now able to order low dose CT scans," Blakely said. "This is another benefit of expanding the eligibility criteria to make sure that we get more patients into the office to be scanned."
As of Feb. 10, Medicare began covering lung cancer screenings with LDCT if all eligibility requirements listed in the National Coverage Determination are met. ACR said 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 to reimburse claims retroactive to the date the final decision memoranda was released.
A Change Request transmittal and a Medicare Learning Network Matters article will be released by CMS that provides instructions to providers and MACs about the implementation of the final policy and updates the Medicare Claims Processing Manual. ACR also said it will continue to update members as information is updated on its Low-Dose CT Lung Cancer Screening FAQ resource page.
How many low-dose lung CT Screening exams are performed each year?
The ACR collects data on these lung CT screen exams in the only CMS-approved lung cancer registry, which began collecting data in February of 2015. Blakey said there were 3,593 facilities performing these low dose lung CT screenings, and they performed 866,954 LDCT lung exams in 2021.
She said additional lung screen information can be found on the ACR website.
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Dave Fornell has covered healthcare for more than 17 years, with a focus in cardiology and radiology. Fornell is a 5-time winner of a Jesse H. Neal Award, the most prestigious editorial honors in the field of specialized journalism. The wins included best technical content, best use of social media and best COVID-19 coverage. Fornell was also a three-time Neal finalist for best range of work by a single author. He produces more than 100 editorial videos each year, most of them interviews with key opinion leaders in medicine. He also writes technical articles, covers key trends, conducts video hospital site visits, and is very involved with social media. E-mail: dfornell@innovatehealthcare.com