June 05, 2024

Comment Today: ACR Seeks Input on Local Medicare Contractor Proposal to Cover AI Technology

Several Medicare Administrative Contractors (MACs) released proposed local coverage determinations (LCDs) expanding coverage of Artificial Intelligence Enabled CT Based Quantitative Coronary Topography (AI-QCT)/Coronary Plaque Analysis (AI-CPA) for Medicare patients. Five of the seven MACs published the proposed LCDs: WPS, Palmetto, Noridian, National Government Services, Inc., and CGS Administrators. The MACs developed policies based on an LCD request for coverage being considered by the Centers for Medicare and Medicaid Services. 

The proposed LCDs indicate that AI-QCT/AI-CPA is medically necessary when the patient: is eligible for coronary computed tomography angiography (CCTA); presents with acute chest pain and no known coronary artery disease and is classified as intermediate risk and/or CAD-RADS 2 and CAD-RADS 3 category on CCTA; and is negative or inconclusive during cardiac evaluation for acute coronary syndrome.

“Ideally, the LCD would include language stating that patients not only with acute chest pain, but also stable chest pain are eligible for AI-QCT/AI-CPA,” said Pamela Woodard, MD, FACR, President of the American College of Radiology® (ACR®).  “Patients with stable angina would most benefit from this technology and the lack of inclusion of stable angina patients may have been an oversight.”

In addition to the medical necessity criteria, the proposed LCDs outline provider qualifications, stating, “Supervision, interpretation, and reports shall/must be performed by a physician with the advanced training requirements and or credentialing for CCTA and AI-QCT/AI-CPA.” The draft policy also points out specific language in the U.S. Food and Drug Administration requirements for the technology indicating that the AI software is “not intended to replace the skill and judgment of a qualified medical practitioner…”

The proposed LCDs are open for public comment until July 13-14. ACR urges members who perform this procedure to engage with the MACs during the public comment period. Physicians and subject matter experts have an opportunity to help improve the clinical indications section and related ICD-10-CM diagnosis codes.

MACs allow 45 days for the medical community to provide oral and/or written comments through open meetings and the public comment period. Interested parties (those that would be affected by the LCD, including providers, physicians, vendors, manufacturers, beneficiaries, caregivers, etc.) can make informational presentations and submit written comments related to the proposed LCD. All comments will be considered by the MACs before the LCD is finalized. Following is the list of MACs, deadlines, contacts and other information:

Medicare Administrative Contractor  Draft LCD  Comment Period Ends Open Meeting Contact
CGS Administrators DL39840 07/14/2024 06/18/2024
4pm ET
Register Here
National Government Services DL39863 07/14/2024 06/20/2024
12pm ET
Register Here
 Noridian Healthcare Solutions, LLC DL39883 J-F
DL39881 J-E
07/13/2024  06/27/2024
2pm CT 
Register Here
Palmetto GBA DL39851 07/14/2024 06/17/2024
10am ET
Register Here
 WPS Insurance Corporation DL39913 07/14/2024 06/27/2024
6pm ET
Join Here


If you have questions or would like more information about local coverage policies and activities, contact Alicia Blakey, ACR Principal Economic Policy Analyst.