CMS Retires NCD 220.6.2 for FDG PET in Lung Cancer — What Billing Teams Need to Know
CMS has formally retired NCD section 220.6.2, the longstanding National Coverage Determination governing FDG PET imaging for lung cancer, replacing it with the consolidated guidance found in NCD section 220.6.17. This administrative change under Policy Code NCD 301 (policy key 301-v3) became effective March 12, 2026, and marks the final retirement of a policy that has technically been superseded since April 3, 2009. If your billing team is still referencing 220.6.2 in documentation, workflows, or payer correspondence, it's time to update your references immediately.
| Field | Detail |
|---|---|
| Payer | CMS (Centers for Medicare & Medicaid Services) |
| Policy | FDG PET for Lung Cancer (Replaced with Section 220.6.17) — RETIRED |
| Policy Code | NCD 301 |
| Change Type | Modified |
| Effective Date | 2026-03-12 |
| Impact Level | Medium |
| Specialties Affected | Radiology, Nuclear Medicine, Pulmonology, Thoracic Surgery, Oncology |
| Key Action | Update all internal policy references, documentation templates, and payer correspondence from NCD 220.6.2 to NCD 220.6.17 immediately. |
What Changed in CMS NCD 301: FDG PET Lung Cancer Policy Retirement
The Centers for Medicare & Medicaid Services has completed the formal removal of NCD section 220.6.2 from the NCD Manual. The revision notice (Rev. 11892) was issued March 9, 2023, with an effective and implementation date of April 10, 2023 — but the administrative update reflected in Policy Code NCD 301 (301-v3) registers the finalized status as of March 12, 2026.
The underlying clinical coverage guidance has not changed. FDG PET coverage for lung cancer is now governed exclusively by NCD section 220.6.17, which serves as the comprehensive, consolidated NCD for PET scans broadly (§220.6). What has changed is the administrative structure: 220.6.2 no longer exists as a standalone reference in the NCD Manual.
For billing teams and RCM directors, the practical risk here is citation drift — using an old section number in prior authorization requests, appeal letters, or medical necessity documentation. Payers reviewing Medicare claims or auditors citing NCD chapters will expect references to point to 220.6.17, not the retired 220.6.2.
Why This Retirement Matters for Radiology and Oncology Billing
The retirement of NCD 220.6.2 is not a surprise. CMS officially replaced it with 220.6.17 back in April 2009 — over 15 years ago. However, the section remained in the NCD Manual in a deprecated state until this revision formally removed it. That's a long window for outdated references to accumulate in billing workflows, payer policy crosswalk documents, and even EHR order sets.
Facilities that have built clinical documentation requirements, prior authorization checklists, or denial appeal templates around language from 220.6.2 should treat this retirement as a hard trigger to audit those materials. Referencing a retired NCD section in a redetermination or reconsideration letter can undermine the credibility of an appeal — even if the underlying clinical argument is sound.
The relevant coverage authority is now NCD §220.6 (PET Scans) and its subsection 220.6.17. That is the document your team should be citing, cross-referencing, and monitoring for future changes.
Understanding the Consolidation: NCD 220.6.17 Is Now the Controlling Document
NCD 220.6.17 is the governing Medicare National Coverage Determination for oncologic PET imaging, including FDG PET in lung cancer diagnostic workups. It consolidates guidance that was previously scattered across condition-specific subsections like 220.6.2.
For lung cancer specifically, coverage under 220.6.17 encompasses FDG PET's role in:
- Diagnosis — characterizing indeterminate pulmonary nodules and distinguishing malignant from benign lesions
- Staging — determining the extent of disease, including mediastinal involvement and distant metastases
- Restaging — evaluating recurrence or response after treatment
- Monitoring therapy response — in appropriate clinical contexts as defined within 220.6.17
Medical necessity documentation should align with the criteria and coverage categories laid out in 220.6.17. If your team is working from documentation templates that cited 220.6.2 indications without verifying alignment with the current 220.6.17 language, that review is overdue.
CMS cross-references this policy to the broader PET Scans NCD at §220.6, which is worth bookmarking for all oncologic imaging workflows.
| 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 301 (301-v3) does not list specific CPT or HCPCS codes. CMS has retired this section as an administrative consolidation rather than a code-level coverage change.
For applicable procedure codes related to FDG PET imaging in lung cancer, billing teams should refer directly to NCD 220.6.17 and the associated claims processing instructions at §220.6, which contain the operative code-level guidance.
Important: Do not rely on this retired section for code-level coverage determinations. The authoritative code and coverage criteria are located in NCD 220.6.17 and the broader PET Scans NCD §220.6.
What Your Billing Team Should Do
| # | Action Item |
|---|---|
| 1 | Audit your documentation templates within the next 30 days. Search for any references to "NCD 220.6.2" or "section 220.6.2" in prior authorization request templates, medical necessity checklists, appeal letter libraries, and payer correspondence templates. Replace every instance with a reference to NCD 220.6.17. |
| 2 | Pull and review NCD 220.6.17 in full. If your team has not recently reviewed the current controlling document, assign a coding lead or RCM director to compare your internal coverage criteria summaries against the language in 220.6.17. Confirm that your clinical documentation requirements for FDG PET lung cancer orders reflect the current NCD, not the retired one. |
| 3 | Brief your denials and appeals team immediately. Any FDG PET claim for a lung cancer indication that is currently in the redetermination or reconsideration pipeline should be reviewed to ensure appeal letters cite 220.6.17, not 220.6.2. A cited retired policy section will not invalidate an appeal outright, but it signals to reviewers that your documentation may not be current — a risk not worth taking. |
| 4 | Update your EHR order sets and payer policy crosswalk documents. If FDG PET ordering workflows within your EHR reference an NCD section number, flag that for your clinical informatics or IT team. Similarly, update any internal payer policy crosswalk that lists NCD 220.6.2 as an active reference. |
| 5 | Monitor NCD 220.6.17 going forward. With 220.6.2 fully retired, all future CMS updates to FDG PET coverage for lung cancer will flow through 220.6.17. Set a policy alert for this section so your team receives notice of any future revisions. |
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