December 2014

The ATS and CHEST jointly submitted comments to the Centers for Medicare and Medicaid Services (CMS) regarding the proposed coverage policy for lung cancer screening. Earlier, CMS has proposed to cover lung cancer screening for Medicare beneficiaries under the following conditions:

• Age 55-74 years;
• Asymptomatic (no signs or symptoms of lung disease);
• Tobacco smoking history of at least 30 pack-years (one pack-year = smoking one pack per day for one year; 1 pack = 20 cigarettes);
• Current smoker or one who has quit smoking within the last 15 years; and
• A written order for LDCT lung cancer screening that meets the following criteria:
  • For the initial LDCT lung cancer screening service:  the beneficiary must receive a written order for LDCT lung cancer screening during a lung cancer screening counseling and shared decision making visit, furnished by a physician [as defined in Section 1861(r)(1) of the Social Security Act (the Act)] or qualified non-physician practitioner (physician assistant, nurse practitioner, or clinical nurse specialist as defined in §1861(aa)(5) of the Act).
  • For subsequent LDCT lung cancer screenings:  the beneficiary must receive a written order, which may be furnished during any appropriate visit (for example: during the Medicare annual wellness visit, tobacco cessation counseling services, or evaluation and management visit) with a physician (as defined in Section 1861(r)(1) of the Act) or qualified non-physician practitioner (physician assistant, nurse practitioner, or clinical nurse specialist as defined in Section 1861(aa)(5) of the Act).

The joint comments submitted by ATS and CHEST thanked CMS for proposing coverage of lung cancer screening, urged CMS to expand the age range to 80-years old, offered perfecting language on identifying the population to be screened, urged a multi-disciplinary approach to the management of lung cancer and noted the appropriateness of multiple shared decision making visits over time. CMS is expected to issue its final coverage policy in the near future.