May 17, 2018

CMS Asked to Clarify LCS Payment Policy for IDTFs

On May 11, 2018, the American College of Radiology (ACR) and partner stakeholders submitted a letter to the Centers for Medicare and Medicaid Services (CMS) urging it to affirm that Independent Diagnostic Testing Facilities (IDTFs) qualify for Medicare reimbursement covering low-dose computed tomography (LDCT) lung cancer screening.

The communication, signed by the ACR, the Radiology Business Management Association (RBMA), the Healthcare Business Management Association (HBMA), the Association for Quality Imaging (AQI), the Medical Imaging and Technology Alliance (MITA), and Lung Cancer Alliance (LCA), is the latest correspondence from the groups seeking CMS confirmation.

In June 2017, CMS provided clarification for coverage of LDCT in IDTFs in MLN Matters® article (MM9246), affirming that IDTFs are eligible for LDCT lung cancer screening coverage when its National Coverage Determination (NCD) criteria are met.

Despite this clarification, Medicare Administrative Contractors (MACs) regularly exclude LDCT lung cancer screening coverage when performed in the IDTF setting, including sites that meet the NCD criteria. MACs assert that screening tests are not eligible for coverage in the IDTF setting. In a February 2018, letter to the ACR, CMS agreed with the MACs’ articles* which state:

“lDTFs are enrolled for diagnostic testing only and are not permitted to perform therapeutic activities (lOM 100-04, Chapter 35). IDTFs may perform the low dose CT scan associated with this benefit (when all requirements for coverage, including a physician's order, are met; see Change Request 9246), but since the code G0297 also includes a therapeutic activity (must make available smoking cessation interventions for current smokers), this service must be billed by a physician. The physician and IDTF must have a business arrangement for cooperatively providing this portion of the benefit and the IDTF shall look to the physician for payment.”

After reviewing the same February 2018 letter, the ACR and fellow stakeholders concluded that the MACs are not correctly adhering to Medicare’s lung cancer screening NCD 210.14. They now urge CMS to publish a Change Request Transmittal notice instructing all MACs that:

  1. LDCT lung cancer screening code G0297 is not an intervention/therapeutic service in the lung cancer screening NCD;
  2. LDCTs are a nationally covered preventive screening service available to Medicare beneficiaries in ALL settings, including IDTFs; and
  3. Payment for all previously performed LDCTs should be retroactive to February 5, 2015, for all imaging facilities, including IDTFs, in accordance with the NCD criteria.

 

The ACR will continue to advocate for lung cancer screening coverage in all settings including IDTFs and to support moving this benefit forward. For more information, contact Kathryn Keysor, ACR senior director of economics and health policy (kkeysor@acr.org).

*Note: Disclaimer must be accepted to view article on CMS webpage.