Positron Emission Tomography (PET) is one of the most powerful and clinically impactful imaging modalities in modern medicine, used to evaluate tissue metabolism in cancer, neurological disorders, and cardiac disease. Coding PET scans correctly is complex, involving a family of six primary CPT codes (78811-78816), additional codes for brain and cardiac studies, mandatory HCPCS radiopharmaceutical codes, Medicare modifier requirements, and National Coverage Determination (NCD) restrictions. A single billing error -- such as a missing PI/PS modifier or incorrect body region code -- can result in immediate claim denial or post-payment audit.
This guide covers every current CPT code, all Medicare NCD requirements, documentation standards, and coding scenarios needed to bill PET scans compliantly in 2026.
The six primary oncologic PET codes are organized into two tiers: codes without a concurrently acquired CT (78811-78813) and codes with a concurrently acquired CT for attenuation correction and anatomic localization (78814-78816). Within each tier, the code is further determined by the body region scanned.
These codes describe PET imaging performed on a dedicated PET-only scanner, or when the CT portion performed on a combined PET/CT system is a separate, stand-alone diagnostic CT (i.e., acquired on a different piece of equipment or interpreted independently as a diagnostic study):
These are the most commonly billed codes in clinical practice today. They describe integrated PET/CT systems where the CT is acquired at the same time, on the same machine, and is used specifically for attenuation correction and anatomic localization of the PET findings:
Critical Distinction: PET vs. PET/CT Code Selection: If the CT scan is performed concurrently on the same integrated PET/CT scanner and its primary purpose is attenuation correction and anatomic localization, use codes 78814-78816. If a truly diagnostic CT is performed separately and independently interpreted, you may report the PET code (78811-78813) plus the appropriate diagnostic CT code with modifier 59 or XU -- but only if performed on separate equipment per NCCI Policy Manual guidance effective January 1, 2018.
flowchart TD
A[PET Scan Ordered] --> B{CT acquired concurrently<br/>on same integrated scanner?}
B -->|Yes| C{Body region?}
B -->|No / PET-only scanner| D{Body region?}
C -->|Limited area| E[78814]
C -->|Skull base to mid-thigh| F[78815]
C -->|Whole body vertex to feet| G[78816]
D -->|Limited area| H[78811]
D -->|Skull base to mid-thigh| I[78812]
D -->|Whole body vertex to feet| J[78813]
E --> K{Oncology indication?}
F --> K
G --> K
H --> K
I --> K
J --> K
K -->|Yes, initial treatment| L[Append modifier PI + A9552]
K -->|Yes, subsequent treatment| M{Scan number for this cancer?}
K -->|No / Non-covered| N[Use G0235]
M -->|1st-3rd scan| O[Append modifier PS + A9552]
M -->|4th+ scan| P[Append modifiers PS + KX + A9552]
For oncologic brain tumor evaluation using 78608, providers must also include modifier QR on the claim and submit ICD-10-CM code Z00.6 on institutional claims. This code is also used for FDG PET in the determination of initial (PI) and subsequent (PS) treatment strategy for brain tumors. Note that 78608 requires a dedicated brain protocol and should NOT be reported when a skull-to-mid-thigh or whole-body protocol incidentally images the brain.
The cardiac PET code family was significantly revised in 2020, when new combination codes and CT add-on codes were introduced:
Every PET scan requires a radiopharmaceutical tracer, and billing the correct HCPCS tracer code on the same claim as the PET CPT code is mandatory under CMS rules. Failure to include the tracer code is a leading cause of PET claim rejections.
For oncologic imaging with proprietary agents, local MACs determine coverage for their FDA-approved labeled indications. Key codes include A9586 (Florbetapir F-18, amyloid brain imaging), A9599 (Piflufolastat F-18/PYLARIFY, PSMA prostate cancer PET), and A9588 (Fluciclovine F-18/Axumin, prostate recurrence PET). Always verify MAC-specific LCDs for coverage of these agents.
Effective January 1, 2025 -- CMS HOPPS Final Rule: In a landmark decision, CMS began paying separately for diagnostic radiopharmaceuticals with per-day costs exceeding $630 under the Hospital Outpatient Prospective Payment System (HOPPS). Previously, virtually all diagnostic radiopharmaceuticals were bundled as "supplies" into the PET procedure payment, often resulting in hospitals receiving inadequate reimbursement for high-cost newer tracers. Under the new policy, high-cost tracers (such as PSMA agents and amyloid PET agents) are now reimbursed on top of the base PET procedure payment, using Mean Unit Cost (MUC) methodology. This change has significantly improved the financial viability of advanced PET imaging at hospital outpatient departments and is expected to expand patient access. The $630 threshold will be updated annually using the Producer Price Index for Pharmaceutical Preparations.
For radiopharmaceuticals billed under the Medicare Physician Fee Schedule (MPFS) at physician offices and IDTFs, the invoice cost for the radiopharmaceutical must be reported in Block 19 of the CMS-1500 form (or electronic equivalent Loop 2400 Segment NTE02) in the format: INV. $00.00. Claims submitted without invoice information are subject to rejection by First Coast and other MACs.
Medicare coverage for PET scans is governed by a series of National Coverage Determinations (NCDs) under Publication 100-03, Chapter 1, Part 4, Section 220.6. Key sub-sections include:
A critical principle: unless a specific use of PET is listed as covered in one of these NCDs, Medicare will not cover it (with the exception that local MACs may cover new proprietary radiopharmaceuticals for their FDA-labeled oncologic indications per a 2013 CMS ruling). Any PET scan performed for a non-covered indication should be billed using G0235.
For all FDG PET oncology claims (CPT codes 78608, 78811-78816 billed with A9552 for cancer indications), CMS requires one of two mandatory modifiers effective for dates of service on or after April 6, 2009:
Denial Alert -- Modifier PS Frequency Limit: Claims for more than 3 FDG PET scans for subsequent treatment strategy (modifier PS, same cancer diagnosis) submitted without modifier KX will be auto-denied by MACs with CARC 96 and RARC N435. The KX modifier certifies that the physician has documented why additional scans beyond the standard allowance are medically necessary for that specific cancer diagnosis.
When PET scans are performed as part of a CMS-approved clinical trial or under Coverage with Evidence Development (CED):
Institutional claims must also include diagnosis code Z00.6 and condition code 30 for clinical trial services. This applies, for example, to NaF-18 (A9580) bone metastasis PET imaging, which is only covered in an approved clinical research study.
The following cancers are among those covered under NCD 220.6.17 for both initial (PI) and subsequent (PS) treatment strategies for FDG PET imaging using codes 78811-78816 and 78608:
Cervical Cancer Exception: There is no Medicare payment for the initial diagnosis of cervical cancer with PET. Cervical cancer is covered only for the detection of pre-treatment metastases (staging) in newly diagnosed cases when conventional imaging is negative for extra-pelvic metastasis. All other cervical cancer PET uses are Coverage with Evidence Development (CED) only.
PET scans are a perennial focus of Medicare audits and Recovery Audit Contractor (RAC) reviews. The ordering physician's documentation must support both the clinical indication and the specific modifier used. Vague orders and incomplete medical records are the primary drivers of post-payment recoupment.
The following documentation elements should be present in the referring/ordering physician's record for every PET scan claim:
| Documentation Element | Non-Compliant (Audit Risk) | Compliant (Audit-Proof) |
|---|---|---|
| Indication | "Cancer surveillance" | "Stage IIIA NSCLC (C34.12), biopsy-confirmed 3/2025, now completing cycle 3 of carboplatin/pemetrexed; PET/CT to assess treatment response and inform subsequent treatment strategy (PS)." |
| Prior Imaging | "Prior CT done" | "CT chest/abdomen 12/2025 showed stable primary lesion but new hilar adenopathy; PET/CT ordered to assess metabolic activity and guide decision regarding consolidation radiation." |
| KX Justification (4th scan) | "Follow-up PET" | "This is the patient's 4th FDG PET scan (modifier PS + KX). Patient completed first-line immunotherapy with partial response; PET medically necessary to determine whether progression has occurred prior to second-line treatment decision." |
When the interpreting physician (radiologist or nuclear medicine physician) and the facility billing the technical component are separate entities, the claim must be split:
Used to unbundle a diagnostic CT from a PET study when a truly separate, full diagnostic CT is performed on the same day. Per NCCI Policy Manual, if the diagnostic CT is obtained on the same PET/CT integrated system for attenuation correction purposes, it cannot be separately billed. However, if performed on separate equipment with a separate diagnostic interpretation, the CT code may be reported with modifier 59 (or XU) appended to the CT code to indicate a distinct service.
Required on the 4th and any subsequent FDG PET scan for PS-modifier oncologic studies with the same cancer diagnosis. Certifies that medical necessity documentation has been created and is maintained in the medical record. Also required on NaF-18 (A9580) bone metastasis PET claims for the professional component to confirm covered indication.
Required when a teaching physician supervises a resident's involvement in the PET scan interpretation. Certifies the teaching physician reviewed the images and participated in the key portions of the service.
This is one of the most frequently misunderstood aspects of PET/CT coding. The rules are:
Common Billing Error: Billing both a PET/CT code (78815 or 78816) AND a separate CT code (e.g., 74178) for the same integrated PET/CT study -- without modifier 59 -- is a known NCCI edit violation and a top cause of post-payment audits and recoupments.
The payment setting significantly affects how PET scans are reimbursed:
PET scans performed in hospital outpatient departments are paid under the OPPS Ambulatory Payment Classification (APC) system. Key features for 2025-2026:
PET scans in non-hospital settings are paid under the Medicare Physician Fee Schedule (MPFS):
Patient: 67-year-old male with biopsy-proven Stage IIIA right upper lobe adenocarcinoma (C34.11). No known distant metastases on CT. PET/CT ordered prior to initiation of concurrent chemoradiation to assess nodal staging.
Equipment: Integrated PET/CT scanner; CT acquired for attenuation correction and localization only (low-dose, non-contrast).
Coding: 78815-PI + A9552 (bill on same claim).
Rationale: PET/CT with concurrent CT (78815), skull base to mid-thigh field of view. PI modifier because this is an initial treatment strategy scan for biopsy-proven cancer. FDG tracer A9552 billed on same claim. No separate CT code may be billed since CT is for attenuation correction only.
Patient: 55-year-old female with diffuse large B-cell lymphoma (C83.30). This is her 4th FDG PET scan since diagnosis. She completed R-CHOP and consolidation radiation. Now on maintenance therapy; oncologist needs PET to assess whether CR is maintained before changing to watchful waiting.
Coding: 78815-PS-KX + A9552.
Rationale: PS modifier for subsequent treatment strategy. KX modifier required because this is the 4th scan under PS for the same cancer diagnosis (C83.30). Medical record must document the specific clinical reason this additional scan is necessary for treatment decision-making. Without KX, the claim auto-denies.
Patient: 48-year-old male with Stage IIC cutaneous melanoma (C43.61) of the right calf. Wide local excision performed. CT shows no thoracic or abdominal metastases, but lower extremity nodes are equivocal.
Coding: 78816-PI + A9552.
Rationale: Whole body code (78816) is required -- not 78815 -- because melanoma staging requires imaging to the feet to rule out distal extremity metastases. PI modifier for initial treatment strategy. Using 78815 would be incorrect because the field of view only extends to mid-thigh and would miss lower leg lesions.
Patient: 72-year-old female with atypical chest pain and a known left bundle branch block (making stress ECG non-interpretable). Cardiologist orders PET myocardial perfusion imaging at rest and pharmacologic stress.
Coding: 78492 + A9555 (Rubidium-82) or A9526 (N-13 Ammonia), depending on tracer used. If concurrent CT for attenuation correction, use 78431 instead.
Rationale: Covered under NCD 220.6.8 for diagnosis of CAD. 78492 is the multi-study (rest + stress) code. Tracer selection depends on what your facility uses -- Rb-82 (A9555) is more common; N-13 Ammonia (A9526) requires an on-site cyclotron. PI/PS modifiers do NOT apply to cardiac PET -- these are oncology-only modifiers.
Patient: 78-year-old male with progressive cognitive decline (G31.9). Clinical presentation is atypical; neurologist cannot distinguish AD from FTD. Neuropsychological testing inconclusive. FDG PET brain requested.
Coding: 78608-Q1 + A9552. If in a CED clinical study: append Q0 or Q1; institutional claims add Z00.6 and condition code 30.
Rationale: NCD 220.6.13 covers FDG PET brain for this specific differential diagnosis. Note: this coverage is strictly limited -- FDG PET is NOT covered for general dementia workup. The clinical record must document that all routine workup has been completed and the differential specifically narrows to AD vs. FTD. Use G30.9 for Alzheimer's disease diagnosis and G31.9 for FTD per current NCD guidance.
| CPT Code | Description | Body Region | Concurrent CT? | Typical Tracer | Common Clinical Use |
|---|---|---|---|---|---|
| 78811 | Tumor imaging, PET; limited area | Single region (e.g., chest, H&N) | No | A9552 (FDG) | Chest-only lung cancer surveillance; H&N tumor evaluation on PET-only scanner |
| 78812 | Tumor imaging, PET; skull base to mid-thigh | Skull base to mid-thigh | No | A9552 (FDG) | Solid tumor staging on PET-only scanner |
| 78813 | Tumor imaging, PET; whole body | Vertex to feet | No | A9552 (FDG) | Melanoma staging on PET-only scanner |
| 78814 | Tumor imaging, PET/CT; limited area | Single region | Yes (integrated) | A9552 (FDG) | Chest-only lung cancer follow-up; H&N restaging on PET/CT |
| 78815 | Tumor imaging, PET/CT; skull base to mid-thigh | Skull base to mid-thigh | Yes (integrated) | A9552 (FDG) | Standard oncology staging/restaging; most commonly billed PET code |
| 78816 | Tumor imaging, PET/CT; whole body | Vertex to feet | Yes (integrated) | A9552 (FDG) | Melanoma; cancers with potential distal extremity involvement |
| 78608 | Brain imaging, PET; metabolic evaluation | Brain only | Optional (use 78608 for standard) | A9552 (FDG) | Brain tumor; AD vs. FTD differential; oncologic brain evaluation |
| 78491 | Myocardial PET; perfusion, single study | Heart | No (use 78430 with CT) | A9555 (Rb-82) or A9526 (N-13 NH3) | CAD evaluation, rest or stress |
| 78492 | Myocardial PET; perfusion, multiple studies | Heart | No (use 78431 with CT) | A9555 (Rb-82) or A9526 (N-13 NH3) | CAD evaluation, full rest + stress protocol |
| 78459 | Myocardial PET; metabolic (viability) | Heart | No (use 78429 with CT) | A9552 (FDG) | Pre-revascularization viability assessment |
| G0235 | PET scan, not otherwise classified | Any | N/A | Any | Non-covered indications; billed to document service but payment is denied by Medicare |
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