CMS Retires NCD 220.6.12 for FDG PET in Soft Tissue Sarcoma — What Billing Teams Need to Know
The Centers for Medicare & Medicaid Services (CMS) has formally retired NCD section 220.6.12, which previously governed FDG PET imaging coverage for soft tissue sarcoma. This retirement under Policy Code NCD 303 (policy key 303-v3) consolidates PET scan coverage guidance under the broader NCD section 220.6.17. If your team has been referencing 220.6.12 for claim support or prior authorization documentation, that section no longer exists in the NCD Manual.
| Field | Detail |
|---|---|
| Payer | CMS (Centers for Medicare & Medicaid Services) |
| Policy | FDG PET for Soft Tissue Sarcoma (Replaced with Section 220.6.17) — RETIRED |
| Policy Code | NCD 303 |
| Change Type | Modified |
| Effective Date | 2026-03-12 |
| Impact Level | Medium |
| Specialties Affected | Oncology, Radiology, Nuclear Medicine, Orthopedic Oncology, Revenue Cycle |
| Key Action | Update all internal billing references, coverage checklists, and prior auth documentation to cite NCD 220.6.17 instead of the now-retired 220.6.12. |
What Changed: CMS Retires NCD 220.6.12 for FDG PET Soft Tissue Sarcoma Coverage
CMS officially removed section 220.6.12 from the NCD Manual, replacing it with section 220.6.17. This consolidation has actually been in effect since April 3, 2009 — but the formal retirement notice (Rev. 11892) was issued March 9, 2023, with an effective and implementation date of April 10, 2023. The 2026 policy record update finalizes this change in the Medicare Coverage Database tracking system.
This is not a coverage elimination. FDG PET for soft tissue sarcoma indications covered under the old section 220.6.12 were rolled into the consolidated PET Scans NCD at section 220.6.17. What changed is the authoritative reference point — and that matters significantly for billing teams that cite NCD sections in appeals, prior authorization requests, or internal coverage determination workflows.
If your documentation templates, LCD cross-reference sheets, or denial appeal letters still cite section 220.6.12, they are pointing to a retired section that no longer exists in the NCD Manual.
Understanding the NCD Structure: 220.6.12 vs. 220.6.17
CMS originally maintained separate NCD subsections for FDG PET coverage across different oncologic indications — each tumor type or clinical scenario had its own numbered section. Over time, CMS consolidated many of these into the overarching PET Scans NCD (§220.6), with section 220.6.17 serving as the current governing reference for oncologic and non-oncologic FDG PET coverage.
For soft tissue sarcoma specifically, the clinical coverage guidance — including any medical necessity criteria, coverage conditions, and limitations — now lives under §220.6.17. Billing and coding teams should pull the full text of that section when building coverage arguments for FDG PET studies in sarcoma patients.
The broader §220.6 NCD covers FDG PET across a wide range of oncologic indications and is the document your team should be referencing for any Medicare claim involving PET imaging. CMS cross-references this explicitly in the retirement notice for 220.6.12.
CMS Medical Necessity and Coverage Framework for FDG PET
Because 220.6.12 has been folded into §220.6.17, the active medical necessity framework is the one established in that consolidated section. The retired NCD 220.6.12 itself contains no standalone indications, criteria, or coverage limitations — it exists only as a pointer to §220.6.17.
For billing purposes, this means:
| # | Covered Indication |
|---|---|
| 1 | Claims citing NCD 220.6.12 as a coverage basis are citing a retired, non-existent section. This could create problems during audits, medical necessity reviews, or appeals if your documentation doesn't reflect the current NCD structure. |
| 2 | The operative policy for FDG PET in soft tissue sarcoma is §220.6.17. Appeals, prior authorization support letters, and ABN documentation should reference this section. |
| 3 | No new restrictions or new coverage expansions were introduced by this retirement. This is an administrative consolidation, not a clinical coverage change. |
Prior Authorization and Claims Documentation Implications
CMS does not require prior authorization for most diagnostic imaging under traditional Medicare fee-for-service, but medical necessity documentation remains critical for audit defense and for Medicare Advantage plans that reference CMS NCDs as their coverage baseline.
If your practice submits FDG PET claims for Medicare beneficiaries with soft tissue sarcoma diagnoses, verify that your:
- Coverage determination templates cite §220.6.17, not 220.6.12
- Denial appeal letter templates reference the current NCD section
- Any Advance Beneficiary Notice (ABN) workflows that reference specific NCD sections are updated
- Medicare Advantage payer contracts or policies referencing the old section are flagged for review — some MA plans explicitly cite CMS NCD sections in their own coverage policies
| 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 document for NCD 303 (303-v3) does not list specific CPT, HCPCS, or ICD-10 codes. All applicable procedure and diagnosis codes governing FDG PET coverage — including those relevant to soft tissue sarcoma — are contained within the consolidated NCD at §220.6.17. Your billing team should consult that section directly for the current code-level guidance.
There are no covered or non-covered code tables to publish from this specific retirement notice, as the operative clinical and coding criteria have fully migrated to §220.6.17.
What Your Billing Team Should Do
| # | Action Item |
|---|---|
| 1 | Immediately audit your documentation templates — Search your internal billing guides, appeal letter templates, ABN workflows, and prior auth support documents for any reference to NCD 220.6.12. Replace every instance with §220.6.17 and the full NCD title (PET Scans). Do this before your next FDG PET claim cycle closes. |
| 2 | Pull and review the full §220.6.17 NCD — Go directly to the CMS Medicare Coverage Database and download the current version of the PET Scans NCD. Confirm that your team understands the medical necessity criteria and coverage conditions that now govern FDG PET for soft tissue sarcoma under the consolidated policy. |
| 3 | Notify your Medicare Advantage audit and appeals staff — Some MA plans write their own coverage policies by citing CMS NCD section numbers. Identify any MA payer policies in your portfolio that may still reference 220.6.12 and flag them for payer outreach or internal documentation updates. |
| 4 | Update your coding and compliance training materials — If your RCM team or coders have reference cards, coverage checklists, or training decks that include CMS NCD section numbers for PET imaging, update those materials to reflect the current NCD structure. Retired section numbers in training content create compliance risk during audits. |
| 5 | Confirm with your EHR or billing system vendor — Some billing platforms include NCD reference fields in their claim scrubbing or coverage check tools. Verify that any hardcoded NCD section references in your system reflect 220.6.17, not the retired 220.6.12. |
Get the Full Picture
Track this policy across versions, search 1,500+ policies by CPT code, and get real-time alerts when any payer changes coverage.