Summary: The Centers for Medicare & Medicaid Services modified its FDG PET for Lymphoma coverage policy, retiring the standalone policy and replacing it with Section 220.6.17, effective May 15, 2026. Here's what billing teams need to know before that date.
This change affects how Medicare covers fluorodeoxyglucose positron emission tomography — FDG PET — for lymphoma staging, restaging, and treatment monitoring. The original standalone policy is now retired. Coverage guidance lives exclusively under the consolidated Section 220.6.17 of the National Coverage Determinations manual. The policy does not list specific CPT or HCPCS codes, so billing teams should cross-reference their current charge capture against the active NCD language directly.
| Field | Detail |
|---|---|
| Payer | CMS |
| Policy | FDG PET for Lymphoma — Retired, Replaced with Section 220.6.17 |
| Policy Code | N/A |
| Change Type | Modified |
| Effective Date | May 15, 2026 |
| Impact Level | High |
| Specialties Affected | Hematology/Oncology, Nuclear Medicine, Radiology, Radiation Oncology |
| Key Action | Update all internal policy references from the retired FDG PET for Lymphoma policy to NCD Section 220.6.17 before May 15, 2026 |
CMS FDG PET for Lymphoma Coverage Criteria and Medical Necessity Requirements 2026
The CMS FDG PET for lymphoma coverage policy has always been one of the more nuanced imaging NCDs. CMS has covered FDG PET for lymphoma under specific medical necessity criteria for years — but that coverage language was scattered across multiple policy documents. Consolidating it under Section 220.6.17 is CMS's way of housekeeping, but it's not a neutral administrative act for your billing team.
Here's what matters: the underlying coverage criteria for FDG PET in lymphoma haven't necessarily changed in clinical substance, but the governing document has. Any internal billing guidelines, payer correspondence templates, or prior authorization workflows your team built around the retired policy need to be updated to reference Section 220.6.17. If your MAC or internal compliance tracking system still points to the old policy, you're working from a retired document. That's a documentation risk on audit.
FDG PET for lymphoma staging and restaging has been a covered Medicare benefit when medical necessity criteria are met — specifically, when the scan is expected to affect patient management. CMS requires that FDG PET be used as a replacement for, or in addition to, conventional imaging when it changes the treatment plan. Coverage historically applied to initial staging, restaging after treatment, and monitoring for suspected recurrence. Section 220.6.17 governs all of this now.
Prior authorization isn't typically required under Medicare FFS for FDG PET in lymphoma, but your Medicare Advantage contracts are a different story. If your patient population includes significant MA volume, verify each plan's prior auth requirements independently — they're not bound by the FFS NCD, even though many use it as a baseline for their own coverage policy language.
The medical necessity documentation burden here is real. Your ordering physicians need to clearly document why FDG PET — rather than CT or conventional imaging — is the appropriate study. "Lymphoma staging" alone doesn't support medical necessity. The documentation should reflect that the PET result will change management. Auditors look for this, and claim denial rates for inadequately documented PET claims remain elevated across oncology practices.
CMS FDG PET for Lymphoma Exclusions and Non-Covered Indications
The retired policy — and the Section 220.6.17 framework that replaces it — has never covered FDG PET for lymphoma as a routine surveillance tool in asymptomatic patients post-treatment. That distinction matters.
CMS draws a clear line between restaging (covered, when medical necessity is documented) and routine surveillance scanning after a confirmed complete remission with no clinical suspicion of recurrence (not covered). If your physicians are ordering follow-up PETs on asymptomatic lymphoma patients at fixed intervals post-treatment, those claims are exposed. The coverage policy requires a clinical reason tied to management change — not a calendar.
Coverage also does not extend to FDG PET when ordered purely for prognostic purposes without documented treatment management implications. CMS's position is that imaging reimbursement requires a clear tie to clinical decision-making. If the scan won't change what the physician does, it doesn't meet medical necessity under this framework.
Coverage Indications at a Glance
| Indication | Status | Relevant Codes | Notes |
|---|---|---|---|
| Initial staging of lymphoma | Covered | Not specified in policy data | Medical necessity documentation required; must reflect management impact |
| Restaging after treatment | Covered | Not specified in policy data | Clinical suspicion of residual or recurrent disease must be documented |
| Monitoring during treatment for suspected recurrence | Covered | Not specified in policy data | Physician documentation must show PET will change management |
| Routine surveillance in asymptomatic post-remission patients | Not Covered | Not specified in policy data | No clinical suspicion of recurrence = no coverage |
| FDG PET for prognostic purposes only | Not Covered | Not specified in policy data | Coverage requires management impact, not prognosis alone |
The policy does not list specific CPT or HCPCS codes. Cross-reference Section 220.6.17 directly for code-level guidance.
CMS FDG PET Lymphoma Billing Guidelines and Action Items 2026
The retirement of the standalone FDG PET for Lymphoma policy isn't a soft change. It's a hard cutover. Before May 15, 2026, your team needs to complete the following:
| # | Action Item |
|---|---|
| 1 | Update all internal policy references. Replace any internal billing guidelines, coding reference sheets, or payer policy databases that cite the retired FDG PET for Lymphoma policy. The controlling document is now Section 220.6.17. Do this before the May 15, 2026 effective date — not after. |
| 2 | Audit your medical necessity documentation templates. Pull your standard PET order templates and physician attestation language. Make sure the language explicitly ties the FDG PET order to a management decision — staging choice, treatment change, or recurrence workup. Generic "lymphoma follow-up" language won't survive a Medicare audit. |
| 3 | Verify your MAC's local guidance. Section 220.6.17 is a National Coverage Determination, but your Medicare Administrative Contractor may have issued a local coverage determination that adds criteria or exclusions specific to your region. Check your MAC's website for any LCD that references FDG PET in lymphoma and confirm it aligns with the new consolidated NCD structure. |
| 4 | Review your Medicare Advantage contracts. MA plans are not bound by CMS FFS NCD requirements. Several large MA payers use their own coverage policy language for FDG PET. Check your Aetna, Cigna Healthcare, and UnitedHealthcare MA contracts separately. Prior authorization requirements, approved indications, and documentation standards can vary significantly from the Medicare FFS baseline. |
| 5 | Run a look-back on recent PET claims for lymphoma. Pull 90 days of FDG PET claims with lymphoma diagnosis codes and spot-check the medical necessity documentation. If you find gaps — orders that say "staging" without management context, or surveillance scans on asymptomatic patients — address those records before an external audit surfaces them. This is also a good time to confirm you're billing the correct PET codes for your scanner type and whether your site has any outstanding coverage questions with your MAC. |
| 6 | Brief your ordering physicians. This policy change is administrative on the surface, but the medical necessity documentation requirements are where claims live or die. Your ordering physicians — oncologists, hematologists, and radiation oncologists especially — need to know that CMS's standard under Section 220.6.17 requires explicit management-change documentation. Schedule a five-minute conversation before May 15, 2026. It's faster than working a denied claim. |
If your practice has high FDG PET volume in oncology or hematology, loop in your compliance officer before the effective date. The shift to Section 220.6.17 is a good trigger to do a broader audit of your PET billing practices.
| 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 |
CPT, HCPCS, and ICD-10 Codes for FDG PET Lymphoma Under Section 220.6.17
The policy data for this change does not list specific CPT, HCPCS, or ICD-10 codes. CMS has not enumerated specific codes within the retirement notice or the replacement section reference provided.
For authoritative code-level guidance, go directly to Section 220.6.17 of the Medicare National Coverage Determinations Manual. Your MAC's website is also the right place to find any associated local coverage determination that maps specific codes to the NCD criteria.
For reference, FDG PET billing for oncology indications typically involves PET procedure codes that your nuclear medicine or radiology billing team uses under the existing CMS oncology PET framework. Do not assume that any codes you were billing under the retired policy are automatically valid under Section 220.6.17 without confirming against the current NCD text. That confirmation step protects your reimbursement and your audit exposure.
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