CMS Retires NCD 220.6.10 for FDG PET in Breast Cancer — What Billing Teams Need to Know

CMS has officially retired NCD 220.6.10, the longstanding coverage policy for FDG-PET imaging in breast cancer, under Policy Code NCD 297 (policy key 297-v3). This administrative change formalizes the replacement of section 220.6.10 with section 220.6.17 in the NCD Manual — a consolidation that has technically been in effect since April 3, 2009, but is now fully codified with a March 2026 effective date. If your facility or practice bills PET scans for breast cancer patients under Medicare, understanding where the authoritative coverage guidance now lives is essential for clean claims and audit readiness.

What Changed in CMS NCD 297 for FDG PET Breast Cancer Coverage

The Centers for Medicare & Medicaid Services issued a revision to NCD Manual section 220.6.10 (Rev. 11892; Issued: 03-09-23; Effective: 04-10-23; Implementation: 04-10-23) formally removing this section from the NCD Manual. The section has been replaced by NCD 220.6.17, which became the operative guidance for FDG PET in breast cancer as of April 3, 2009.

What this means practically: section 220.6.10 no longer exists as an active policy reference point in the Medicare NCD Manual. Any internal billing documentation, coverage determination checklists, or payer policy trackers that still cite 220.6.10 are pointing to a retired and removed section. The March 2026 action by CMS finalizes this housekeeping — but it also signals that CMS is actively auditing and cleaning up its NCD Manual, which can precede more substantive coverage changes down the line.

The benefit category for this service remains Diagnostic Tests (other) under Medicare. This categorization matters for claims routing and remittance review.

Where Medicare FDG PET Coverage for Breast Cancer Now Lives

All active Medicare coverage criteria for FDG-PET in breast cancer patients are now exclusively governed by NCD 220.6.17, accessible through the Medicare Coverage Database under NCD §220.6 (PET Scans). CMS explicitly cross-references §220.6 as the authoritative source for PET scan coverage determinations.

If your billing team or compliance staff have been using 220.6.10 as a reference — whether in coverage determination workflows, ABN (Advance Beneficiary Notice) processes, or denial appeal letters — those references are now outdated and potentially misleading in an audit context. Appeals that cite retired policy sections can raise red flags with Medicare Administrative Contractors (MACs), even when the underlying clinical documentation is solid.

It's also worth noting that Local Coverage Determinations (LCDs) from individual MACs may provide additional specificity for FDG-PET in breast cancer beyond what the NCD establishes at the national level. Now that the NCD consolidation is formalized, MACs have clearer ground to build LCD guidance on top of 220.6.17. Watch for LCD activity in your region.

Why This "Administrative" Change Carries Real Compliance Risk

Policy retirements often get dismissed as bookkeeping. They aren't — at least not from a revenue cycle standpoint. Here's why this one warrants attention:

Appeals and redetermination letters citing NCD 220.6.10 will now reference a policy that CMS has formally removed from its manual. While a MAC reviewer may understand the historical context, citing a retired NCD section weakens an appeal on its face and could result in unnecessary denials at higher levels of review.

Payer audit trails increasingly rely on policy version history. If your practice was credentialing or conducting internal compliance reviews against 220.6.10, those records need to be updated to reflect the active policy reference.

Vendor and clearinghouse edits in some RCM platforms may still carry the old NCD reference. If your system flags or approves breast cancer PET claims based on an internal crosswalk to 220.6.10, that crosswalk needs immediate correction.

The bottom line: a retired NCD section is a liability, not a technicality.

Affected Codes

This policy does not list specific CPT, HCPCS, or ICD-10 codes in the retirement notice itself. Per CMS, applicable code-level coverage criteria for FDG-PET in breast cancer are contained within the replacement policy, NCD 220.6.17, and the broader PET scan NCD at §220.6. Billing teams should consult those active sections directly for procedure codes and covered diagnosis codes.

No codes are listed in the NCD 297 (v3) retirement notice. Do not attempt to bill against NCD 220.6.10 — it is no longer an active section of the NCD Manual.

What Your Billing Team Should Do