SNMMI Opposes Proposed LCD to Restrict Care for Patients

May 26, 2023

In the late Spring 2023, SNMMI submitted comments to the Medicare Administrative Contractor (MAC) in Tennessee for the Centers of Medicare and Medicaid Services (CMS). The Society urged the withdrawal of the proposed Local Coverage Determination (LCD), Positron Emission Tomography (PET) Scan for Inflammation and Infection (DL39521), in order to further evaluate the potential far-reaching implications of implementation on the practice of nuclear medicine.

More specifically, SNMMI communicated that FDG PET is a valuable problem-solving tool that should be available to physicians to help in the diagnosis of patients—often critically ill patients who have no other diagnostic test options—and further rejected the claim of overuse in patients with suspected inflammation/infection.

The proposed LCD incorrectly rejects PET coverage and wrongly classifies the following treatments as experimental and investigational:

  • Fever of unknown origin (FUO) in immunocompromised patients
  • Native endocardial valve infections
  • Joint arthroplasty
  • Chronic osteomyelitis
  • Diabetic foot
  • Spondylodiscitis

SNMMI recommended that, at minimum, MACs cover all indications that have an appropriate use criteria score of 7 or higher. Additionally, SNMMI recommended coverage for all patients with FUO, regardless of category, as this patient population is especially susceptible to unusual infectious agents and more rapid diagnosis is often needed.

SNMMI strongly encouraged the MAC in Tennessee to reevaluate the proposed LCD and recommended substantial revisions to align with clinical evidence.

CMS MAC CSG SNMMI comment letter