August 30, 2023

ACR Submits Comments on CMS Proposed Transitional Coverage for Emerging Technologies Pathway

The American College of Radiology® (ACR®) submitted comments in response to the Centers for Medicare and Medicaid Services (CMS) proposed Transitional Coverage for Emerging Technologies (TCET) pathway to improve the Medicare coverage process when making decisions on certain emerging technologies at the national level. In our letter, we provide several recommendations to strengthen the TCET pathway. We continue to track policy developments on this topic as previously reported.

ACR concurs with CMS that new approaches are needed to make coverage decisions on certain new items and services to provide expedited access to emerging innovative medical technologies. We support accelerating the Medicare coverage determination process and making it more transparent.

The College also supports the development of a voluntary, time-limited pathway for emerging technologies. However, we have some concerns about the proposed program's scope and utility.

In the past, ACR submitted comments through rulemaking for the Medicare Coverage of Innovative Technologies (MCIT)/Reasonable and Necessary (R&N) final rule that was repealed in November 2021. We are pleased with the modifications made to the program for TCET, but additional improvements are necessary. We look forward to the final procedural notice and CMS’ plans for implementation and will continue to keep members abreast of new information.

If you have questions regarding TCET or Medicare coverage activities, contact Alicia Blakey, ACR Principal Economic Policy Analyst.