CMS Lung Cancer Screening (LDCT) Coverage Policy Updated: What Billing Teams Need to Know

The Centers for Medicare & Medicaid Services has modified NCD 364, its national coverage determination governing lung cancer screening with low-dose computed tomography (LDCT). This update carries significant implications for radiology practices, pulmonology groups, and primary care billing teams who order or perform LDCT screenings for Medicare beneficiaries. Here's exactly what changed, who qualifies, and what your revenue cycle team should do before claims start landing in 2026.

Field	Detail
Payer	CMS (Centers for Medicare & Medicaid Services)
Policy	Lung Cancer Screening with Low Dose Computed Tomography (LDCT)
Policy Code	NCD 364 (v2)
Change Type	Modified
Effective Date	March 12, 2026
Impact Level	High
Specialties Affected	Radiology, Pulmonology, Primary Care, Thoracic Surgery, Internal Medicine
Key Action	Audit your patient population and documentation workflows against the updated eligibility criteria before the March 12, 2026 effective date.

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CMS LDCT Coverage Policy: What NCD 364 Actually Covers

Lung cancer remains the leading cause of cancer-related deaths in the United States—responsible for over 130,000 deaths in 2021 alone, which exceeds the combined estimated deaths from colon, breast, and prostate cancer. The median age at death is 72 years, placing this squarely within the Medicare population.

Under §1861(ddd) of the Social Security Act, CMS has authority to cover "additional preventive services" through the NCD process when three statutory requirements are met: the service must be (1) reasonable and necessary for prevention or early detection of illness or disability, (2) recommended with a grade of A or B by the United States Preventive Services Task Force (USPSTF), and (3) appropriate for Part A or Part B beneficiaries. LDCT lung cancer screening meets all three thresholds under NCD 364.

Coverage under this NCD falls under the Medicare Part B Additional Preventive Services benefit category. The foundational coverage date for the current criteria is February 10, 2022, with the March 12, 2026 modification date representing the version now in effect.

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Medicare LDCT Beneficiary Eligibility Criteria: The Full Checklist

This is where claims get denied. Every single one of the following criteria must be met before Medicare will cover annual LDCT lung cancer screening. There's no flexibility here—NCD 364 is explicit that all criteria apply simultaneously.

Beneficiaries must meet ALL of the following:

• Age: 50–77 years
• Symptomatic status: Asymptomatic—no signs or symptoms of lung cancer
• Smoking history: At least 20 pack-years (1 pack-year = 1 pack per day for 1 year; 1 pack = 20 cigarettes)
• Smoking status: Current smoker OR someone who has quit within the last 15 years
• Order: Must have a physician or qualified provider order for lung cancer screening with LDCT

The age range—50 to 77 years—is a detail that catches billing teams off guard. Beneficiaries aged 78 and older are not covered under this NCD, regardless of smoking history or clinical presentation. Screen your scheduling system to flag orders outside this window before they reach the claim stage.

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The Counseling and Shared Decision-Making Visit Requirement

Before a beneficiary's first LDCT screening, a counseling and shared decision-making visit must occur and be appropriately documented in the medical record. This isn't optional—it's a condition of coverage.

That visit must include all four of the following components:

1. Determination of beneficiary eligibility (confirming all criteria above are met)
2. Shared decision-making, including the use of one or more decision aids
3. Counseling on adherence to annual LDCT screening, the impact of comorbidities, and the beneficiary's ability or willingness to undergo diagnosis and treatment
4. Smoking cessation counseling—for current smokers, the importance of quitting and, if appropriate, information about tobacco cessation interventions; for former smokers, the importance of maintaining abstinence

If documentation of this visit is incomplete or missing, the subsequent LDCT screening claim is at risk. Billing teams should confirm that the ordering provider's note explicitly addresses all four components before claim submission.

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Facility and Radiologist Eligibility Requirements

Coverage isn't just about the patient—it extends to where the scan is performed and who reads it.

Reading radiologist: Must be board certified or board eligible with the American Board of Radiology or an equivalent organization.

Radiology imaging facility: Must use a standardized lung nodule identification, classification, and reporting system. In practice, this means facilities typically use Lung-RADS (Lung Imaging Reporting and Data System), though the NCD references a standardized system broadly rather than mandating a specific proprietary tool.

Facilities that cannot document compliance with a standardized reporting system should not be billing for LDCT lung cancer screening under Medicare until that gap is addressed.

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Non-Covered Indications Under NCD 364

CMS is direct on this point: preventive services are non-covered by Medicare unless specifically addressed within NCD 364 or another applicable NCD. If a beneficiary does not meet all the eligibility criteria outlined above—wrong age bracket, symptomatic presentation, insufficient smoking history, or lack of a qualifying order—the service is not covered.

Symptomatic patients are explicitly excluded. If a patient presents with hemoptysis, unexplained weight loss, or other signs of possible lung cancer, the clinical workup shifts from preventive screening to diagnostic imaging—a different benefit category with different billing and coverage rules entirely.

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Affected Codes

The policy document for NCD 364 (v2) does not list specific CPT or HCPCS codes within the version of the policy summary provided. Billing teams should reference the CMS Claims Processing Manual and the Medicare Physician Fee Schedule to confirm the current applicable codes for:

• The LDCT screening scan itself
• The counseling and shared decision-making visit (billed separately from the scan)

Work with your coding team or a qualified medical coder to ensure you're using the correct codes in conjunction with any applicable preventive service modifiers required by your MAC (Medicare Administrative Contractor).

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What Your Billing Team Should Do

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