The latest update to the American College of Radiology (ACR) Lung Cancer Screening FAQs, posted Feb. 5, clarifies that any “treating physician” may perform the shared decision-making (SDM) consultative visit based on further clarification from the Centers for Medicare and Medicaid Services (CMS). In addition, updates were included based on slight changes to the Medicare Physician Fee Schedule (MPFS) conversion factor for year 2016.
The ACR recommended to CMS a revision or clarification be included in their MLN Matters article that currently states “NOTE: For outpatient hospital settings, as in any other setting, services covered under Medicare’s National Coverage Determination (NCD) must be ordered by a primary care provider within the context of a primary care setting and performed by an eligible Medicare provider for these services,” as this language may have unintended consequences and result in potential confusion.
The ACR agrees with the Feb. 5, 2015 NCD language that specifies that a physician or qualified non-physician practitioner must perform the shared-decision making visit. As defined in §1861(r) of the Social Security Act (the Act), a “treating physician” is a physician who furnishes a consultation or treats a beneficiary for a specific medical problem, and who uses the results of a diagnostic test in the management of the beneficiary’s specific medical problem. It further defines an “order” as a communication from the treating physician/practitioner requesting that a diagnostic test be performed for a beneficiary. CMS also described relevant provider qualifications in the CMS Manual-Transmittal 80.
CMS clarified to several professional organizations on Feb. 1, 2016 that “the National Coverage Determination (NCD) for Lung Cancer Screening with LDCT (210.14) is based on the recommendation of the U.S. Preventive Services Task Force (USPSTF), whose general focus is the primary care provider and setting. We recognize the NCD does not specifically state primary care physician or setting. Based on the NCD and applicable regulations, the physician or non-physician practitioner who furnishes the shared-decision making visit and orders the LDCT must be treating the beneficiary and use the results in the management of the beneficiary's specific medical problem to ensure improved health outcomes.”
Providers and practices must meet all coverage criteria to be reimbursed by Medicare for CT lung cancer screening exams. These frequently asked questions and answers, prepared by the ACR, address coverage and reimbursement requirements relating to patient eligibility, center eligibility, accreditation and lung cancer screening designation, radiologist requirements, clinical practice registry, and billing and payment.
Click here to access the FAQs.