With over 250 signatures, ASTRO’s comment letter opposing the billing of image guidance codes with superficial radiation therapy (SRT) has been sent to CMS. In the letter, ASTRO highlights the lack of clinical benefit, expressing alarm at the growing use of “image guided” superficial radiation therapy. ASTRO urges CMS to reconsider the NCCI PTP edits that allow for image guidance to be billed in conjunction with SRT.

The continued billing of image guidance codes to treat SRT performed by dermatologists threatens the value of these codes. Additionally, the "imaging" performed by the superficial treatment machines does not match the work described in the code descriptions. The image guidance process requires a mathematical linkage between the imaging system and the radiation delivery system, which does not exist in the ultrasound systems used for this vendor specific technique.

ASTRO appreciates membership support of the sign-on letter and will provide updates once they become available.