CMS Retires NCD 220.6.7 for FDG PET in Head and Neck Cancers — What Billing Teams Need to Know
CMS has officially retired NCD section 220.6.7, the longstanding Medicare coverage policy for FDG PET imaging in head and neck cancers, replacing it with the consolidated section 220.6.17. This change under Policy Code NCD 305 (policy key 305-v3) was issued March 9, 2023, with an effective date of April 10, 2023—and the retirement entry itself is now formally marked in the NCD Manual as of March 12, 2026. If your billing team is still referencing the old section number for claims documentation or prior authorization support, you're pointing to a retired policy.
| Field | Detail |
|---|---|
| Payer | CMS (Centers for Medicare & Medicaid Services) |
| Policy | FDG PET for Head and Neck Cancers (RETIRED) — NCD 220.6.7 |
| Policy Code | NCD 305 (305-v3) |
| Change Type | Modified (section retired, replaced by 220.6.17) |
| Effective Date | April 10, 2023 (retirement formalized March 12, 2026) |
| Impact Level | Medium — coverage itself has not been eliminated, but the authoritative policy reference has changed |
| Specialties Affected | Oncology, Head & Neck Surgery, Nuclear Medicine, Radiation Oncology, Radiology, RCM teams billing PET imaging |
| Key Action | Update all internal policy references, LCD cross-walks, and prior auth documentation from NCD 220.6.7 to NCD 220.6.17 immediately |
What Changed in CMS NCD 305: The Retirement of Section 220.6.7
CMS's National Coverage Determination Manual is organized into numbered sections, and for years, NCD 220.6.7 served as the specific Medicare policy anchor for FDG PET scans in head and neck cancer indications. That section has been formally removed from the NCD Manual.
The replacement is NCD 220.6.17, which consolidates PET scan coverage policy under a single, updated section. This consolidation happened back in 2009—effective April 3, 2009—but the administrative retirement of 220.6.7 has now been fully formalized with a revision date of March 9, 2023, and implementation confirmed April 10, 2023.
The March 2026 update to policy key 305-v3 reflects the formal record-keeping change that billing teams need to register: the old section number is gone, and any policy citation work needs to flow through the new section.
Why This Matters for Head and Neck Cancer PET Billing
This is not a coverage elimination. Medicare has not stopped covering FDG PET for head and neck cancers. But that nuance is exactly what makes this type of administrative retirement easy to mishandle.
Here's where the risk lives for your revenue cycle:
- Prior authorization documentation that cites NCD 220.6.7 may raise flags during payer review or audits, since the section no longer exists in the active NCD Manual.
- Medical necessity letters and appeal submissions referencing the retired policy number look outdated and can undermine otherwise solid clinical arguments.
- Internal LCD/NCD reference libraries maintained by your billing or compliance team need to be updated. A stale policy reference in a denial appeal is an avoidable error.
- Third-party billing software and payer policy databases may still carry the old section number if they haven't incorporated the 2023 and 2026 updates. Verify your tools reflect the change.
The Centers for Medicare & Medicaid Services consistently expects that claims and supporting documentation reference current, active policy sections. While a retired section number alone is unlikely to trigger a claim denial, it creates compliance exposure—especially during post-payment audits and RAC reviews.
CMS Coverage Framework for FDG PET: The Active Policy is NCD 220.6.17
All Medicare coverage guidance for FDG PET scans—including head and neck cancer indications—now lives under NCD 220.6.17, which falls within the broader PET Scans NCD at §220.6. That umbrella NCD governs the diagnostic test benefit category for PET imaging across oncologic and non-oncologic indications.
For billing purposes, the benefit category classification remains Diagnostic Tests (other) under the Medicare benefit framework.
The cross-reference CMS has embedded in the retired 220.6.7 record points directly to the PET Scans NCD (§220.6), which is the appropriate place to confirm current coverage criteria for head and neck cancer PET imaging going forward.
If you're building or maintaining a payer policy matrix for your oncology or radiology group, §220.6 and the sub-section 220.6.17 are the correct anchors. Pull the active policy from the CMS Medicare Coverage Database at the link cited in the official cross-reference.
| 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 305 (305-v3) does not list specific CPT or HCPCS codes. This is consistent with the administrative nature of the retirement entry—code-level coverage criteria are contained within the active replacement policy, NCD 220.6.17.
Action required: Pull applicable procedure codes (including FDG PET CPT codes relevant to head and neck oncology imaging) directly from NCD 220.6.17 in the CMS Medicare Coverage Database. Do not rely on the retired 220.6.7 record for code-level guidance.
What Your Billing Team Should Do
| # | Action Item |
|---|---|
| 1 | Update your internal NCD reference library by end of this week. Remove any entries pointing to NCD 220.6.7 as an active policy. Replace with NCD 220.6.17 and the parent §220.6 PET Scans NCD. Note the effective date of April 3, 2009, for the consolidation and April 10, 2023, for the formal retirement. |
| 2 | Audit your prior authorization templates and medical necessity letter language. Search for any document that cites "220.6.7" and update citations to reflect the current section. This includes appeal letters, authorization request narratives, and coverage determination summaries used by your clinical staff. |
| 3 | Verify your third-party billing or RCM software reflects the retirement. Contact your vendor if NCD 220.6.7 still appears as an active policy in their system. Stale policy data in billing tools is a compliance liability. |
| 4 | Pull the full active coverage criteria from NCD 220.6.17. Confirm that your team understands the current medical necessity thresholds and documentation requirements for FDG PET in head and neck cancer under the active policy—not the retired one. |
| 5 | Flag this change for your compliance and coding education calendar. Physicians and advanced practice providers documenting medical necessity for head and neck PET studies should know that the policy framework has been formally consolidated. Documentation that tracks to the right NCD section strengthens your audit defense posture. |
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