On June 12, 2017, the Centers for Medicare and Medicaid Services (CMS) revised their MLN Matters® article (MM9246) and clarified that Independent Diagnostic Testing Facilities (IDTFs) are eligible for low-dose computed tomography (LDCT) lung cancer screening coverage when national coverage criteria are met. This CMS clarification is effective February 5, 2015. If you are an IDTF entity that has met the National Coverage Decision (NCD) criteria, please be encouraged to submit claims to your local Medicare contractor as per MM9246.
The following language is the relevant section from CMS (MM9246):
As part of the NCD, all criteria listed in the NCD must be met to include requirements for reading radiologists and radiology imaging facilities. In addition to collecting and submitting data to a CMS-approved registry, all facilities that would like to be eligible to perform the lung cancer screening, including Independent Diagnostic Testing Facilities (IDTFs), must meet all criteria stated in the Decision Memo for Lung Cancer Screening with LDCT, which is available at https://www.cms.gov/medicare-coverage-database/details/nca-decision-memo.aspx?NCAId=274. Information regarding CMS-approved registries is posted at: http://www.cms.gov/Medicare/Medicare-General-Information/MedicareApprovedFacilitie/Lung-Cancer-Screening-Registries.html on the CMS website.
The American College of Radiology (ACR) in collaboration with key stakeholders, have continued to advocate for lung cancer screening coverage performed in ALL facilities, including IDTFs, and applaud CMS for their written clarification. Medicare published national lung cancer screening coverage in Feb. 2015. However, implementation of this life-saving screening exam has been denied in the IDTF setting due to Medicare Administrative Contractors (MACs) misinterpretation of the lung cancer screening national coverage decision.
Numerous MACs have improperly excluded LDCT lung cancer screening coverage across the board, when performed in the IDTF setting, even for those sites that meet the NCD criteria. Certain MACs have not considered whether NCD criteria are met in an IDTF facility and have misinterpreted the IDTF regulations regarding diagnostic radiology exams erroneously excluding screening exams. Diagnostic radiology encompasses both diagnostic and screening exams.
In addition, many MACs have misinterpreted the lung cancer screening NCD “Radiology Imaging Facility” criteria and incorrectly defined as an “intervention” and their basis for excluding IDTFs from coverage consideration. The NCD states “making available smoking cessation interventions for current smokers.” An example of meeting this criteria, include educational stop smoking brochures and sometimes a referral onto those specialists that can provide intervention/therapy, etc. The screening imaging exam is not an interventional or therapeutic service.
MACs also have misunderstood the registry requirements tied to the lung cancer screening NCD and inaccurately deemed IDTFs ineligible to enroll in the CMS-approved registry. The ACR lung cancer screening registry allows ALL entities to enroll and submit data. In addition, CMS clarified in their MLN Matters® article that all facilities including IDTFs that would like to be eligible to perform lung cancer screening must meet the NCD criteria and collect and submit data to the CMS-approved registry.
The June 12, 2017 CMS clarification regarding IDTFs reconfirms that Medicare beneficiaries have had the lung cancer screening benefit since Feb. 5, 2015 in ALL settings including IDTFs. It is important to help educate your Medicare contractors on this CMS clarification. To this end, the ACR and other keys stakeholders submitted written comments to all MAC jurisdictions and requested they revise their IDTF policies to reflect this essential Medicare health benefit and to make payments retroactive to Feb. 5, 2015. Although CMS has not provided explicit instructions on retroactive claims submissions, please note the MM9246 is listed with an effective date of Feb. 5, 2015.
Erroneous MAC denials have impacted Medicare patients over the last several years resulting in patient access issues and decreased screening rates. The ACR will continue to monitor lung cancer screening coverage in all settings including IDTFs and help move this life-saving benefit forward.
Please contact your local MAC with specific questions regarding IDTF lung cancer screening claims processing. Provided below are the additional resources and MAC directory links included in MM9246.
The official instruction, CR9246, consists of two transmittals:
1. Transmittal R3374CP, which updates the “Medicare Claims Processing Manual"
2. Transmittal R185NCD, which updates the “Medicare NCD Manual”
If you have any questions, please contact your MAC at their toll-free number. That number is available on this webpage.