CMS PET Scan Heart Perfusion Coverage: What Billing Teams Need to Know About NCD 292
CMS has issued a modification to National Coverage Determination (NCD) 292, which governs Medicare coverage for positron emission tomography (PET) scans used for cardiac perfusion imaging. This update, effective March 12, 2026, touches one of the more nuanced areas of cardiovascular billing—where the relationship between PET and SPECT imaging directly determines whether a claim will be paid or denied. If your practice or facility bills for cardiac PET perfusion studies, understanding exactly what CMS requires is essential before submitting claims.
| Field | Detail |
|---|---|
| Payer | CMS (Centers for Medicare & Medicaid Services) |
| Policy | PET for Perfusion of the Heart |
| Policy Code | NCD 292 |
| Change Type | Modified |
| Effective Date | 2026-03-12 |
| Impact Level | Medium |
| Specialties Affected | Cardiology, Nuclear Medicine, Radiology, Cardiovascular Surgery |
| Key Action | Audit current cardiac PET workflows to confirm PET is billed as a replacement for—or post-inconclusive follow-up to—SPECT, not as an add-on study. |
What CMS NCD 292 Actually Covers: Cardiac PET Perfusion Rules
The Centers for Medicare & Medicaid Services covers cardiac PET perfusion imaging under two distinct radiopharmaceutical pathways, each with its own effective date and documentation requirements. Both pathways follow the same core coverage logic, but your billing team needs to understand both to avoid claim denials.
Rubidium 82 (Rb 82) — Covered from March 14, 1995
CMS covers PET scans performed at rest or with pharmacological stress for noninvasive imaging of cardiac perfusion using the FDA-approved radiopharmaceutical Rubidium 82. Coverage applies to patients with known or suspected coronary artery disease (CAD). The study must meet at least one of two conditions:
- The PET scan is performed in place of—not in addition to—a SPECT study, or
- The PET scan is performed following a SPECT that was inconclusive, where the PET was determined necessary to decide on appropriate medical or surgical intervention.
Ammonia N-13 — Covered from October 1, 2003
The same coverage rules apply to PET perfusion imaging using FDA-approved ammonia N-13. At rest alone or rest with pharmacological stress, the study must replace SPECT or follow an inconclusive SPECT. The medical necessity standard and documentation requirements are identical to the Rb 82 pathway.
The PET vs. SPECT Replacement Rule—The Most Common Billing Error
The most critical concept in NCD 292 is the replacement rule, and it's also where claims most frequently go wrong. CMS will not pay for a cardiac PET perfusion study that is ordered as a supplemental or concurrent study alongside SPECT imaging. The policy is explicit: PET is covered when it substitutes for SPECT or when it follows a SPECT that produced inconclusive results.
An inconclusive SPECT—for NCD 292 purposes—is one whose results are equivocal, technically uninterpretable, or discordant with the patient's other clinical data. Critically, the inconclusive nature of the prior SPECT must be documented in the beneficiary's medical record. A verbal note or assumption that the test was inadequate is not sufficient. Your clinical documentation must specifically reflect why the SPECT was inconclusive and why the PET was then considered necessary for treatment planning.
This is a documentation gap that auditors will find. If your facility performs high volumes of cardiac imaging, a targeted internal audit of your PET-after-SPECT cases is worth doing before CMS does it for you.
Medical Necessity Criteria Under CMS NCD 292
To summarize the coverage criteria cleanly, CMS requires all of the following to establish medical necessity for a covered cardiac PET perfusion study:
| # | Covered Indication |
|---|---|
| 1 | Patient population: Known or suspected coronary artery disease |
| 2 | Radiopharmaceutical: Either Rb 82 (covered from March 14, 1995) or ammonia N-13 (covered from October 1, 2003) — both must be FDA-approved |
| 3 | Modality basis: PET replaces SPECT, or PET follows an inconclusive SPECT |
| 4 | If following inconclusive SPECT: Documentation in the beneficiary's file must confirm the SPECT was equivocal, technically uninterpretable, or discordant with clinical data |
| 5 | Clinical necessity: The PET must have been considered necessary to determine what medical or surgical intervention the patient requires |
Studies performed with rest alone or rest plus pharmacological stress both qualify, provided the above criteria are met. Note that exercise stress is not part of the pharmacological stress pathway described in this NCD—pharmacological agents are the standard here.
Historical Claims Submission Requirements You May Still Encounter
For dates of service prior to July 1, 2001, CMS required claimants to submit specific G codes on the claim form when billing cardiac PET with Rb 82. Those codes indicated the results of the PET scan and whether it followed an inconclusive prior noninvasive cardiac test. If the prior test was inconclusive, the claim also required documentation specifying the type of test performed and its inconclusive status.
Beginning July 1, 2001, standard appropriate codes replaced those legacy G codes. While most billing teams will never touch pre-2001 claims, this detail matters if you're working through old accounts receivable, responding to reopening requests, or handling RAC audit appeals on aged claims.
Cross-Referenced CMS Policies Billing Teams Should Know
CMS NCD 292 does not stand alone. The policy explicitly cross-references two related national coverage determinations your team should have on file:
- NCD for PET Scans (§220.6) — the broader PET coverage framework
- NCD for SPECT (§220.12) — the coverage rules governing the imaging modality that PET must replace or follow
Coverage decisions under NCD 292 can only be fully understood in context with these related policies. If a claim is denied and the denial cites a coverage conflict, the answer may lie in how these three NCDs interact.
| Previous Version | Current Version |
|---|---|
| Coverage is considered experimental and investigational for all indications | Coverage is considered medically necessary when specific criteria are met |
| Prior authorization is not required | Prior authorization is required for initial treatment |
| Documentation must include clinical history | Documentation must include clinical history |
| Re-review every 24 months | Re-review every 12 months with updated clinical documentation |
Affected Codes
The policy data for NCD 292 does not list specific CPT or HCPCS codes within the NCD document itself. Billing teams should reference the CMS Medicare Coverage Database directly and consult the Claims Processing Transmittals (TN 1817 and TN 1833) for applicable billing codes. Standard cardiac PET perfusion imaging is typically reported using codes your MAC (Medicare Administrative Contractor) has mapped to this NCD—confirm current code assignments with your MAC or through your billing software's payer policy crosswalk.
No ICD-10-CM diagnosis codes are enumerated in the NCD 292 policy document. Diagnosis coding should reflect the patient's known or suspected CAD status and align with the medical necessity criteria above.
What Your Billing Team Should Do
| # | Action Item |
|---|---|
| 1 | Audit your PET-after-SPECT claims before March 12, 2026. Pull a 90-day sample of cardiac PET perfusion claims where SPECT was also billed. Confirm each claim documents either that PET replaced SPECT or that SPECT was inconclusive—and that the inconclusive finding is in the medical record, not just the ordering note. |
| 2 | Update your clinical documentation templates now. Work with your cardiology or nuclear medicine team to ensure that orders for cardiac PET perfusion include a structured documentation element: either a statement that PET is being ordered in lieu of SPECT, or a specific notation that prior SPECT was inconclusive with a reason (equivocal results, technically uninterpretable, or discordant with clinical data). |
| 3 | Confirm your radiopharmaceutical documentation is claim-ready. Your claims must reflect use of an FDA-approved agent—either Rb 82 or ammonia N-13. Ensure your charge capture process records the specific agent used, not just a generic PET perfusion code, so the claim accurately reflects the covered service. |
| 4 | Pull TN 1817 and TN 1833 and confirm current billing codes with your MAC. Since NCD 292 does not enumerate specific CPT or HCPCS codes within the policy text, your Medicare Administrative Contractor is the authoritative source for code-to-NCD mapping. Verify this mapping is current in your billing system. |
| 5 | Brief your prior authorization team on the replacement rule. If your payer mix includes Medicare Advantage plans that follow CMS NCDs, ensure your PA requests for cardiac PET explicitly address the SPECT replacement or inconclusive SPECT criteria. A PA approval that doesn't align with NCD 292 medical necessity language can still produce a medical necessity denial at claims adjudication. |
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