CMS Retires NCD 220.6.15 for FDG PET Scans: What the Section 296 Update Means for Your Billing Team

CMS has officially retired NCD 220.6.15—the coverage section governing FDG PET scans for all other cancer indications not previously specified—and replaced it with section 220.6.17 under the broader PET Scans NCD (§200.6). This change, reflected in policy code NCD 296 (policy key 296-v3) with a modification date of March 12, 2026, closes out a long-standing housekeeping gap in the NCD Manual that has existed since the original replacement took effect April 3, 2009. If your billing team is still referencing 220.6.15 in any internal documentation, compliance checklists, or payer correspondence, it's time to update those references now.

What CMS Changed in NCD 296: Retiring Section 220.6.15 for FDG PET Coverage

The Centers for Medicare & Medicaid Services issued revision 11892 to formally remove NCD section 220.6.15 from the NCD Manual. The revision was issued March 9, 2023, with an effective and implementation date of April 10, 2023—and this 2026 policy record update reflects the finalized state of that retirement within the NCD 296 framework.

To be clear about the timeline: CMS actually replaced 220.6.15 with 220.6.17 back on April 3, 2009. What happened in 2023—and what is now reflected in this 2026 NCD 296 update—is the formal, administrative removal of the old section from the NCD Manual itself. Think of it as CMS finally taking down the old road sign after the road was rerouted 14 years earlier.

For billing and RCM teams, the practical implication is straightforward: section 220.6.15 no longer exists as a citable authority. All FDG PET coverage determinations for cancer indications not previously specified now live under NCD 220.6.17, which is part of the umbrella PET Scans NCD at §200.6.

Understanding the FDG PET Coverage Framework Under CMS

FDG (fluorodeoxyglucose) PET scans are among the more complex imaging categories in Medicare coverage policy because they are governed by multiple NCD subsections, each addressing specific cancer types and clinical indications. The §220.6 family of NCDs broke out coverage rules by cancer indication—with dedicated subsections for diagnoses like lung cancer, esophageal cancer, colorectal cancer, lymphoma, melanoma, and others.

Section 220.6.15 was designed as a catch-all for "all other cancer indications not previously specified"—essentially a bucket for FDG PET use cases that didn't fit the explicitly named cancer types in earlier subsections. When CMS consolidated and updated those rules into 220.6.17 in 2009, the intent was to bring broader and more flexible coverage determinations under a single, updated framework.

Now that 220.6.15 is fully retired and removed from the NCD Manual, citing it in any clinical justification, appeal letter, or prior authorization request is not just outdated—it references a section that CMS has formally erased from the record.

CMS FDG PET Billing: Why the Controlling Section Matters

For billing managers and RCM directors, the section number in an NCD isn't just an administrative detail—it's the foundation of your medical necessity argument. When you're submitting claims for FDG PET scans under Medicare, or appealing a denial, the coverage criteria you cite need to come from the active, controlling NCD section.

Appeals and ADR responses that reference 220.6.15 could be dismissed on procedural grounds or raise compliance red flags during audits. Medicare Administrative Contractors (MACs) follow the active NCD Manual, and a retired section carries no coverage authority.

The controlling authority for FDG PET scans across cancer indications is now NCD §200.6, with the specific rules for indications not previously specified housed in section 220.6.17. Any team building denial appeal templates, medical necessity letters, or LCD cross-reference guides should reflect this structure.

Benefit Category and Claims Processing Notes

CMS classifies FDG PET scans under the Diagnostic Tests (other) benefit category for Medicare purposes. This classification affects how claims route through Medicare systems and what Part B cost-sharing rules apply.

The NCD 296 policy record does not include a separate claims processing instruction beyond the cross-reference to §200.6. This is consistent with the nature of this update—it's a retirement and redirect, not a substantive coverage rule change. The clinical and billing rules live in 220.6.17 and the broader PET NCD.

Affected Codes

The policy does not list specific CPT, HCPCS, or ICD-10 codes within this NCD 296 record. The retirement of section 220.6.15 is an administrative action pointing billing teams to the active codes and criteria housed under NCD §200.6 (PET Scans) and section 220.6.17.

For the applicable procedure codes governing FDG PET scans under Medicare, consult the full PET Scans NCD directly at the CMS Medicare Coverage Database.

Common HCPCS codes associated with FDG PET imaging for oncologic indications—such as A9552—are governed by the active NCD sections and any applicable LCD policies issued by your regional MAC. Do not rely on NCD 296 or section 220.6.15 for code-level guidance.

What Your Billing Team Should Do