Coalition urges CMS clarification on low dose CT guidance

May 24, 2018
by Thomas Dworetzky, Contributing Reporter
The American College of Radiology (ACR) and other partner groups have sent a formal letter to the U.S. Centers for Medicare and Medicaid Services (CMS) requesting that it confirm that Medicare will reimburse for CT lung cancer screening at Independent Diagnostic Testing Facilities (IDTF).

Its partners include the Radiology Business Management Association (RBMA), the Healthcare Business Management Association (HBMA) the Association for Quality Imaging (AQI), Medical Imaging and Technology Alliance (MITA), and Lung Cancer Alliance (LCA).

“We believe that Medicare Administrative Contractors (MACs) are not correctly adhering to the lung cancer screening NCD 210.14. In accordance with the June 12, 2017 Medicare Learning Network Matters article (MM9246), CMS clarified that IDTFs are, in fact, eligible facilities capable of performing low-dose computed tomography (LDCT) lung cancer screening. Nevertheless, MACs regularly exclude LDCT lung cancer screening coverage when performed in the IDTF setting, including at sites that meet the NCD criteria. We hope CMS can clarify these outstanding issues contributing to the MACs’ decision to deny coverage of LDCT lung screening at IDTFs,” the letter stated.

ACR noted in a May 18th statement that physician ignorance of screening guidelines, lack of patient and physician education about screening and “drastically low Medicare reimbursement for low-dose computed tomography (LDCT) lung cancer screening exams” may be resulting in thousands of unnecessary deaths each year.

“CT lung cancer screening can save more lives than any cancer screening test in history, but patients are not hearing about this test from their doctors,” said Dr. Ella Kazerooni, ACR Lung Cancer Screening Committee Chair, in a statement. “Medicare is not adequately covering these exams. This noncompliance and practical non-coverage is contributing to unnecessary deaths due to lack of screening.”

The ACR letter to CMS requested clarification and advised that MACs are misinterpreting the regulations by “erroneously” excluding the screening exams.

“MACs continue to approve payment to IDTFs for 71250 (non-contrast chest CT), while denying LDCT lung cancer screen (G0297), despite being the same type of service (e.g., chest CT). The MACs state that IDTFs are for diagnostic testing, rather than screening.”

The coalition members view this narrow definition of diagnostic exam as erroneous. The MACs, according to the letter, continue to view the screens as “therapeutic intervention.” The coalition letter requested that CMS issue a notice to MACs establishing that they are, in fact, diagnostic, a preventive screening available to Medicare users, that it should be covered wherever it is given, including IDTFs, and that payment should go back to February 5, 2015.

Lung cancer screenings were in the news in January when twin studies in Annals of Internal Medicine showed that using them based on individual risk could potentially save more lives than current recommendations but could be pricey, and not offer substantial gains in life-years saved or quality-adjusted-life-years (QALYs).

The first, from researchers at the National Cancer Institute (NCI), compared the eligibility criteria of the U.S. Preventive Services Task Force (USPSTF).

“There is growing consensus in the field that the current USPSTF guidelines may exclude some smokers at high risk of lung cancer who could also benefit from lung cancer screening,” Li C. Cheung, an NCI statistician and one of the coauthors of the first study, told HCB News. “The use of individualized risk calculators and individualized risk-based screening could guard against such exclusion of high-risk smokers from screening. Future screening guidelines may well incorporate individualized risk-based screening thresholds for the selection of smokers.”

Researchers at Tufts Medical Center conducted the second study, which looked at the cost-effectiveness of a risk-targeted screening strategy against criteria of the National Lung Screening Trial by estimating the QALYs gained, relative to the cost of screening.

Though targeting low-dose CT (LDCT) was found to more likely detect cancer in high-risk patients and avert death over all seven years of the trial, such patients were found to be older, with greater smoking exposure, and more likely to have a preexisting diagnosis of chronic obstructive pulmonary disease, giving them a shorter life expectancy and lower quality of life, according to the researchers.

Researchers concluded that preventing death in such patients produced fewer QALYs than in those with lower risk.