CMS Retires NCD 220.6.4 for FDG PET in Colorectal Cancer — What Billing Teams Need to Know

CMS has officially retired NCD 220.6.4, the longtime National Coverage Determination governing FDG-PET scanning for colorectal cancer, and replaced it with the consolidated PET scan policy at section 220.6.17. This change, reflected in policy code NCD 299 (policy key 299-v3), was issued March 9, 2023, with an effective and implementation date of April 10, 2023—and its retired status is now formally documented with a March 12, 2026 modification date. If your revenue cycle team is still routing colorectal cancer PET claims by referencing the old NCD section, you're pointing to a dead address.

What Changed: CMS NCD 220.6.4 Is Officially Retired and Replaced

The Centers for Medicare & Medicaid Services removed section 220.6.4 from the NCD Manual effective April 3, 2009, consolidating colorectal cancer FDG-PET coverage guidance under the broader PET Scans NCD at section 220.6.17. What's happening now—more than 15 years later—is a formal housekeeping action that updates the NCD Manual record to reflect that retirement, closes out the old section in the coverage database, and directs all cross-references to §220.6.

This matters for billing teams because the NCD database is a living document. Revenue cycle staff, coders, and compliance teams who pull policy citations directly from the CMS Medicare Coverage Database need to know that any documentation, denial appeal letter, or authorization request that cites §220.6.4 is referencing a section that no longer exists in the manual. The controlling policy is §220.6 (the general PET Scans NCD, NCDId=211), which houses §220.6.17 as the active governing section for oncologic and non-oncologic PET indications—including colorectal cancer.

Benefit Category and Claim Classification Under CMS

For Medicare billing purposes, FDG-PET for colorectal cancer falls under the Diagnostic Tests (other) benefit category. This classification affects how claims are structured, which fee schedule applies, and how medical necessity documentation should be framed.

CMS notes that the Diagnostic Tests benefit category may not be an exhaustive list of all applicable Medicare benefit categories for this item or service. In practice, this means billing teams should verify the applicable benefit category in the context of the full claim—especially for inpatient versus outpatient settings—and not assume a single benefit category controls reimbursement in every scenario.

The Active Policy: Where to Find Colorectal Cancer PET Coverage Rules Now

All FDG-PET coverage determinations for colorectal cancer are now governed by NCD §220.6.17, accessible through the main PET Scans NCD (NCDId=211, version 2) in the CMS Medicare Coverage Database. That consolidated NCD covers the full range of oncologic PET indications and is where CMS sets out:

• Which cancer types and clinical scenarios qualify for Medicare coverage
• Distinctions between covered indications and non-covered or investigational uses
• Any requirements for coverage with evidence development (CED) or clinical trial enrollment
• Documentation and medical necessity standards applicable to FDG-PET studies

Billing and coding teams should pull §220.6.17 directly from the CMS coverage database and ensure your internal policy library is updated to that citation. Any payer correspondence, LCD cross-reference documents, or CDM (charge description master) annotations tied to colorectal cancer PET imaging should be updated accordingly.

Affected Codes

The policy document for NCD 299-v3 does not list specific CPT, HCPCS, or ICD-10 codes. This is consistent with a retirement/consolidation action—the applicable procedure codes are now governed by the active policy at §220.6.17, not this retired section. Billing teams should reference the live PET Scans NCD (NCDId=211) for the current applicable code set.

No covered, non-covered, or experimental codes are enumerated in this retirement notice.

Why This Type of Policy Housekeeping Still Matters for Revenue Cycle

Retired NCD entries that linger in internal policy libraries are a known source of denial exposure and compliance risk. Here's why this specific retirement notice deserves attention beyond a quick read:

Appeal letters and medical necessity documentation. If your team uses templated language for prior authorization requests or denial appeals, those templates may cite §220.6.4 by name or number. A MACs (Medicare Administrative Contractor) reviewer who pulls the NCD Manual will find that section gone—potentially undermining an otherwise solid clinical argument.

Compliance audits. When payers or OIG auditors review medical necessity documentation for PET claims, they check that clinical criteria align with the controlling NCD. Citing a retired section raises questions about whether the documentation was current at the time of service.

MAC LCD alignment. Local Coverage Determinations issued by MACs often cross-reference specific NCD sections. If an LCD in your jurisdiction cited §220.6.4, that LCD may have been updated—or it may still carry the outdated reference. Either way, your team needs to know which controlling document applies.

What Your Billing Team Should Do