On March 9, 2021, GO2 for Lung Cancer, American College of Radiology (ACR), and the Society of Thoracic Surgeons (STS) urged the Centers for Medicare and Medicaid Services (CMS) to revise their Medicare coverage policy to reflect the new U.S. Preventive Services Task Force (USPSTF) eligibility thresholds and remove barriers that keep at-risk populations from accessing these lifesaving exams. We were pleased to see CMS’ response and Draft National Coverage Decision (NCD) that proposes a lower smoking history (20 pack-years) criterion and an earlier screening starting age (50 years). However, we did not agree with select CMS screening criteria that restrict and negatively impact an at-risk population previously outlined in our June 2021 letter.

Our joint societies (GO2 for Lung Cancer, ACR, STS) called on CMS to move quickly and expand screening to the Medicare population including the most vulnerable and underserved.  On December 16, 2021, we submitted formal recommendations to CMS reiterating our initial concerns, responding to CMS’ November 2021 Draft NCD and again urging Medicare to strengthen their Proposed NCD by removing the following barriers.

Recommendations to CMS:

  • Delete the annual screening eligibility criterion that discontinues screening once an individual reaches age 78.
  • Delete the screening eligibility criterion that discontinues annual screening for individuals who quit smoking for more than 15 years.
  • Remove the “Counseling and Shared Decision Making” requirement to ensure the current National Coverage Determination (NCD) language does not act as a barrier to screening uptake.
  • Maintain the Radiology Imaging Facility Eligibility Criteria for Quality Assurance.

Although we commend CMS for expanding the screening eligibility criteria in the Draft NCD, more work is still needed to reduce barriers and increase screening uptake for the at-risk Medicare population.  GO2 for Lung Cancer will continue to closely monitor the NCD process and anticipate a final CMS coverage decision in February 2022.

The CMS NCD timeline is posted on the CMS tracking sheet for low dose CT lung cancer screening. Any questions regarding this coverage decision can be addressed to Anita McGlothlin, Health Policy Director at amcglothlin@go2.org.