April 8, 2009
Cardinal Health
CMS Publishes Decision to Expanded Coverage of PET for Oncology Indications

The Centers for Medicare and Medicaid Services (CMS) has published their final decision memo for Positron Emission Tomography (FDG) for Solid Tumors and Myeloma (CAG-00181R).

The decision includes the following major changes to coverage of PET for oncology indications:
  1. Coverage Framework change
    CMS has adopted a new coverage framework that replaces the four-part diagnosis, staging, restaging and monitoring response to treatment categories with a two-part framework:
    • Initial Anti-tumor Treatment Strategy, formerly “diagnosis” and “staging”
    • Subsequent Anti-tumor Treatment Strategy, formerly “restaging” and “monitoring response to treatment”
  2. Expand Coverage of the Initial Anti-tumor Treatment Strategy
    CMS has determined the evidence is adequate to determine that the results of FDG PET imaging are useful in determining the appropriate initial treatment strategy for beneficiaries with suspected solid tumors and myeloma. Therefore, CMS will cover only one FDG PET study for beneficiaries who have solid tumors that are biopsy proven or strongly suspected based on other diagnostic testing when the beneficiary’s treating physician determines that the FDG PET study is needed to determine the location and/or extent of the tumor for the following therapeutic purposes:
    • To determine whether or not the beneficiary is an appropriate candidate for an invasive diagnostic or therapeutic procedure; or
    • To determine the optimal anatomic location for an invasive procedure; or
    • To determine the anatomic extent of tumor when the recommended anti-tumor treatment reasonably depends on the extent of the tumor.

    Restrictions: PET is not covered by CMS for initial treatment strategy evaluation for three specific cancer types/indications: 1) diagnosis and axillary nodal staging of breast cancer; 2) assessment of regional lymph nodes in melanoma; and 3) diagnosis of prostate cancer and initial staging of newly diagnosed prostate cancer.

    PET for initial treatment strategy evaluation is covered only with participation in the National Oncologic PET Registry (NOPR) for certain patients with suspected or proven cervical cancer and for patients with suspected or proven leukemia.

    The decision expands the national coverage of FDG PET for broad use in solid tumors and myeloma and for the covered indications eliminates the requirement to go through the NOPR.
  3. Continue to Restrict Coverage for the Subsequent Anti-tumor Treatment Strategy
    The use of FDG PET for assessment of the success of the initial treatment strategy to determine the need for and content of a subsequent treatment strategy is covered by CMS for the following cancers: breast, cervix, colorectal, esophagus, head and neck (non-CNS/thyroid), lymphoma, melanoma, non-small cell lung, thyroid, ovarian, and myeloma.

    For all other cancers, PET coverage for subsequent treatment strategy evaluation requires participation in an approved Coverage with Evidence Development Program i.e. the NOPR.

Effect of Coverage Changes on Oncologic Uses of FDG PET (Note: Coverage with Evidence Development (CED) means participation in the NOPR; new nationally covered indications are in red text)

  Final Framework
Solid Tumor Type Initial Treatment Strategy* Subsequent Treatment Strategy**
Colorectal Cover Cover
Esophagus Cover Cover
Head & Neck (not thyroid or CNS) Cover Cover
Lymphoma Cover Cover
Non-small cell lung Cover Cover
Ovary Cover Cover
Brain Cover CED
Cervix 1 or CED Cover
Small cell lung Cover CED
Soft Tissue Sarcoma Cover CED
Pancreas Cover CED
Testes Cover CED
Breast (female and male) 2 Cover
Melanoma 3 Cover
Prostate N/C CED
Thyroid Cover 4 or CED
All other solid tumors Cover CED
Myeloma Cover Cover
All other cancers not listed herein CED CED

* Formerly “diagnosis” and “initial staging”
** Formerly “restaging” and “monitoring response to treatment when a change in treatment is anticipated” (coverage includes treatment monitoring, restaging and detection of suspected recurrence)
N/C = noncovered


(1) Cervix: Covered for the detection of pre-treatment metastases (i.e., staging) in newly diagnosed cervical cancer subsequent to conventional imaging that is negative for extra-pelvic metastasis. All other uses are CED.
(2) Breast: Noncovered for diagnosis and/or initial staging of axillary lymph nodes. Covered for initial staging of metastatic disease.
(3) Melanoma: Noncovered for initial staging of regional lymph nodes. All other uses for initial staging are covered.
(4) Thyroid: Covered for subsequent treatment strategy of recurrent or residual thyroid cancer of follicular cell origin previously treated by thyroidectomy and radioiodine ablation and have a serum thyroglobulin >10ng/ml and have a negative I-131 whole body scan. All other uses for subsequent treatment strategy are CED.
Note: According to an official at CMS the implementation date (i.e. when CMS contractors will be able to process claims for the new nationally covered indications) will be July 3, 2009. The official also indicated that CMS is expected to publish program Transmittals within the next 2 – 3 weeks which will formally update the National Coverage Determinations Manual and Claims Processing Manual for PET with confirmation of the implementation date and any new coding information (i.e. the use of modifiers) that must be used for claims processing.

Cardinal Health will publish eNews updates as more information becomes available.

For additional information please read the following article posted on the Society of Nuclear Medicine website: interactive.snm.org/index.cfm?PageID=8598&RPID=10

For detailed information regarding changes to the NOPR please visit: www.cancerpetregistry.org/index.htm

The CMS final decision memo can be found at: www.cms.hhs.gov/mcd/viewdecisionmemo.asp?id=218#AppA

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