The Reading Room

A comprehensive guide to CMS's lung cancer screening proposal

by Solomon Banjo

Going against MEDCAC’s recommendation in April this year, CMS released a proposal last night to cover low-dose CT (LDCT) lung cancer screening for high-risk patients.

CMS’s proposed rule will be open for a thirty day public commenting period and the final rule will be released in February of next year. The rule makes lung cancer screening available for high-risk patients aged 55-74 years, mandates shared decision making prior to the first scan, and sets eligibility criteria for the radiologists and imaging centers able to perform the exam.

Read on to find out the patient, provider and clinician requirements contained in CMS’s new rule, then try our new lung cancer screening toolkit to get our expert guidance for your screening program.

Introducing the Lung Cancer Screening Toolkit

Making the case for lung cancer screening to your stakeholders? Download our ready-to-use physician, patient, and employer marketing materials, just a few of the many resources in our Lung Cancer Screening Program Toolkit. Learn about these materials and more at our webconference on Wednesday, Nov. 19.

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CMS uses NLST age recommendation for high-risk patients

In order to qualify for lung cancer screening coverage under CMS’s proposed rule, patients must meet the following eligibility criteria:

  • Age 55-74 years
  • Have no signs or symptoms of lung disease
  • Have a tobacco history equivalent to smoking a pack a day for thirty years (30 pack-years)
  • Be a current smoker or one who has quit smoking within the last 15 years
  • Have a written order for LDCT lung cancer screening received during a lung cancer screening counseling and shared decision making visit
    • For subsequent screenings a beneficiary must receive a written order during an appropriate visit with a physician or non-physician practitioner (physician assistant, nurse practitioner, or clinical nurse specialist).

CMS’s age restrictions mirror those from the NLST, but differ from the USPSTF’s recommendation which recommends coverage for patients through age 80.

CMS sets requirements for what constitutes a shared decision making visit

Our research revealed that shared decision making is an essential part of a comprehensive lung cancer screening programs. CMS chose to mandate shared decision making visits occur before a patient receives their first order for lung cancer screening. The shared decision making visit must include:

  • Determination of patient’s eligibility according to the criteria listed above
  • The use of one or more decision aids covering benefits, harms, follow-up diagnostic testing, over-diagnosis, false positive rate, and total radiation exposure
  • Counseling on the importance of adherence to annual LDCT lung cancer screening, impact of comorbidities and ability or willingness to undergo diagnosis and treatment
  • Counseling on the importance of maintaining cigarette smoking abstinence if former smoker, or smoking cessation if current smoker and, if appropriate, offering additional Medicare-covered tobacco cessation counseling services

The screening order must include the patient’s date of birth, pack-year smoking history (number), current smoking status, statement the patient is asymptomatic and NPI of the ordering physician. The details of the shared decision making visit must be documented in the patient’s medical record.

CMS sets eligibility criteria for participating radiologists and imaging centers to address critics

One of the concerns voiced by MEDCAC and other critics of lung cancer screening is that most real world application of lung cancer screening would not mirror the conditions of the NLST. To that end CMS has created eligibility criteria for radiologists and imaging centers that seek to offer lung cancer screening.

Radiologists must:

  • Have current certification with the American Board of Radiology or an equivalent organization
  • Have documented training in diagnostic radiology and radiation safety
  • Have involvement in the supervision and interpretation of at least 300 chest CT acquisitions in the past 3 years
  • Have documented participation in continuing medical education in accordance with the current American College of Radiology standards.

Participating imaging centers must:

  • Either have participated in past lung cancer screening trials or be an accredited advanced diagnostic imaging center with training and experience in LDCT lung cancer screening
  • Use LDCTs with an effective radiation dose of 1.5mSv
  • Collect and submit data to a CMS-approved national registry for each LDCT lung cancer screening performed.
    • Details on what the data must include can be found here

What this means for imaging

CMS’s decision to support LDCT lung cancer screening means that all high-risk patients will have access to the screening exam regardless of whether they have public or private insurance. It also means that we can expect the impressive growth in lung cancer screening programs to continue.

CMS’s criteria requiring shared decision making and eligibility measures highlights the fact that lung cancer screening programs are more than just a radiologist and a scanner. Enhance your own lung cancer screening offerings by using our latest toolkit.