CMS Retires NCD 220.6.6 for FDG PET in Melanoma — What Billing Teams Need to Know

CMS has officially retired NCD 220.6.6, the longstanding Medicare coverage policy governing FDG PET imaging for melanoma, and replaced it with section 220.6.17 under the broader PET Scans NCD (§220.6). This change, reflected in Policy Code NCD 304 (policy key 304-v3), was issued March 9, 2023 with an effective and implementation date of April 10, 2023—and the retirement is now formally codified in the NCD Manual. If your practice or facility is still referencing 220.6.6 in documentation, internal policies, or payer correspondence, it's time to update your records.

What Changed: CMS Retires NCD 220.6.6 for FDG PET Melanoma Coverage

The Centers for Medicare & Medicaid Services has formally removed section 220.6.6 from the NCD Manual. This section previously governed Medicare coverage determinations for FDG (fluorodeoxyglucose) positron emission tomography scans performed in the diagnosis, staging, and restaging of melanoma patients.

The retirement is not a coverage elimination—it is a consolidation. CMS moved the melanoma-specific PET guidance into the unified PET Scans NCD under section 220.6.17, effective April 3, 2009. The March 2023 revision simply formalized the removal of the old section from the manual, closing out the legacy reference that many billing teams had been using for years.

This matters because outdated NCD citations in your documentation, appeals correspondence, or MAC communications can create unnecessary friction during claims review or audits.

Understanding the Transition from NCD 220.6.6 to NCD 220.6.17

The consolidation of FDG PET melanoma coverage under §220.6.17 has been in effect since 2009—but many revenue cycle teams continue to reference the old section number. Here's why that's a problem:

When auditors, MACs, or reviewers look up NCD 220.6.6, they now find a retired policy with a redirect notice. If your team is citing a retired NCD in medical necessity documentation or appeals letters, it signals outdated processes and can undermine the credibility of your submission.

The authoritative reference going forward is the PET Scans NCD at §220.6, specifically subsection 220.6.17, which consolidates melanoma indications alongside other oncologic and non-oncologic PET applications. All billing documentation, prior authorization requests, and internal coding guidelines should reflect this updated cross-reference.

Why This Retirement Matters for Oncology and Radiology Billing

For oncology practices, radiology groups, and hospital outpatient departments billing Medicare for FDG PET in melanoma patients, the administrative implications are real—even though the underlying coverage criteria have been housed in §220.6.17 for over a decade.

Documentation and templates: Any superbills, order forms, or medical necessity templates that reference NCD 220.6.6 must be updated. Using a retired NCD citation won't necessarily trigger an automatic denial, but it introduces ambiguity that can slow down claims processing or raise flags during post-payment review.

Appeals and reconsiderations: If you have open appeals that cite NCD 220.6.6 as the coverage authority, revise those submissions before they're adjudicated. Citing the active policy (§220.6.17) strengthens your position.

Medicare Advantage plans: MA plans that mirror CMS NCDs may not immediately update their systems to reflect the retirement. If you encounter an MA payer still referencing 220.6.6 in their coverage policies or EOBs, it's worth flagging that the NCD has been retired and the active policy is §220.6.17.

Benefit Category and Coverage Framework

Under the Medicare benefit structure, FDG PET for melanoma falls under Diagnostic Tests (other) — the same benefit category that covered it under the retired 220.6.6 framework. That classification has not changed with the retirement.

The applicable coverage criteria, indications, and limitations for FDG PET in melanoma are now governed entirely by the PET Scans NCD at §220.6.17. Billing teams should pull and review that section directly from the CMS NCD Manual to confirm current coverage requirements, including any oncologic indication-specific conditions that apply to melanoma staging and restaging scenarios.

Affected Codes

The policy data for NCD 304 (policy key 304-v3) does not list specific CPT, HCPCS, or ICD-10 codes. This is consistent with the retirement notice format — the active code-level guidance resides in the replacement policy at §220.6.17.

For the applicable procedure codes associated with FDG PET imaging, billing teams should reference the current PET Scans NCD (§220.6 and §220.6.17) directly in the CMS Medicare Coverage Database.

What Your Billing Team Should Do