Reimbursement & Billing

AI Lung Nodule Analysis Has a
Medicare Reimbursement Pathway

CPT codes 0721T and 0722T cover quantitative CT tissue characterization of lung nodules, with a $650.50 Medicare OPPS base rate per analysis. Oatmeal Health is building LungAI to fit squarely within this existing payment pathway post FDA 510(k) clearance.

1

CT Scan Acquired

LDCT performed or prior imaging available

2

AI Tissue Characterization

Quantitative analysis generates Malignancy Risk Score

3

Report & Bill

Physician report filed, claim submitted to Medicare

CMS already pays for AI-driven quantitative CT tissue characterization of lung nodules under dedicated Category III CPT codes established by the AMA in July 2022. These codes are active, assigned to a specific APC, and carry a national payment rate today.

Oatmeal Health's LungAI platform is designed to perform exactly this type of analysis: quantitative tissue characterization that generates malignancy risk scores to support radiologists and pulmonologists. Once LungAI receives FDA 510(k) clearance, providers will be able to bill for LungAI analyses under the same codes that CMS already reimburses.

LungAI is an investigational medical device and has not been cleared by FDA. Oatmeal Health is preparing a 510(k) premarket notification for submission to FDA. LungAI is not commercially available in the United States. Clinical performance data reflect retrospective studies on held-out datasets; results may differ in prospective use.
CPT Codes

Dedicated Codes for CT Tissue Characterization

Two Category III CPT codes cover AI-driven quantitative analysis of lung nodules, whether performed on prior imaging or alongside a new CT scan.

Standalone
0721T

Quantitative computed tomography (CT) tissue characterization, including interpretation and report, obtained without concurrent CT examination

When to use

Bill this code when the AI analysis is performed on a previously acquired CT scan. The patient does not need to be present for a new scan. Common scenario: a radiologist reviews a prior CT and runs quantitative tissue characterization on an existing nodule finding.

Billing status

This is a standalone code. It is billed independently.

Effective: July 1, 2022

Add-on
+0722T

Quantitative computed tomography (CT) tissue characterization, including interpretation and report, obtained with concurrent CT examination

When to use

Bill this code when the AI analysis is performed at the same encounter as a new CT scan. The quantitative tissue characterization is an add-on to the primary CT procedure. Common scenario: patient comes in for a follow-up CT and the analysis is run on the new images during the same visit.

Billing status

This is an add-on code. It must be billed alongside the primary CT procedure code for the concurrent scan, including low-dose lung cancer screening CT (71271) and chest CT (71250, 71260, 71270).

Effective: July 1, 2022

Both codes are Category III CPT codes assigned by the AMA to track emerging technologies. Category III codes are generally archived five years after publication unless extended by the AMA. In 2026, both codes are paid separately under OPPS at the New Technology APC 1508 rate, before coinsurance and wage index adjustments. You cannot bill both 0721T and 0722T for the same patient encounter.

Medicare Payment

APC 1508: $650.50 Per Analysis

CMS has assigned CPT 0721T and +0722T to Ambulatory Payment Classification 1508 (New Technology, Level 8) under the Hospital Outpatient Prospective Payment System.

$650.50

National Base Rate

Medicare OPPS base payment for CPT 0721T and +0722T under APC 1508 (CY 2026). Actual payments vary by geographic wage index.

APC 1508

Payment Classification

New Technology, Level 8. CMS recognition of the clinical value of AI-driven lung nodule analysis.

SI: S

Status Indicator

Significant procedure. Not discounted when performed alongside other procedures in the same encounter.

Why This Matters for LungAI

Many AI diagnostic tools face a "reimbursement gap," where no payment pathway exists even after FDA clearance. For quantitative CT tissue characterization of lung nodules, that gap does not exist. CMS has already established the APC, set a national rate, and providers are billing under these codes today.

Oatmeal Health is building LungAI to align directly with the clinical workflow these codes describe. Once LungAI achieves FDA 510(k) clearance, providers may report 0721T or +0722T where the service meets the code descriptor. Payment is subject to medical necessity, Medicare contractor coverage, and annual OPPS rulemaking. LungAI is investigational and not FDA 510(k) cleared.

The Status Indicator "S" classification means both codes are paid at the full APC rate under OPPS even when performed alongside other outpatient procedures. There is no OPPS multiple-procedure discount. Payment amounts are updated annually in the CMS OPPS Final Rule and may vary by geographic region due to wage index adjustments.

Diagnosis Codes

Supporting ICD-10-CM Codes

Claims for CPT 0721T and 0722T require a supporting ICD-10-CM diagnosis code. The following codes cover the primary clinical scenarios for AI-driven lung nodule analysis.

ICD-10-CM Code Description Clinical Scenario
R91.1 Solitary pulmonary nodule Single lung nodule found on CT imaging. Most common primary diagnosis for nodule characterization.
R91.8 Other nonspecific abnormal finding of lung field Multiple nodules or other lung findings requiring further characterization.
Z87.09 Personal history of other diseases of the respiratory system Prior respiratory disease with follow-up nodule evaluation.
Z12.2 Encounter for screening for malignant neoplasm of respiratory organs Lung cancer screening encounter. Used when analysis is part of a screening workflow.
Z87.891 Personal history of nicotine dependence Former smoker. Commonly paired with nodule follow-up and screening workflows.
F17.210 Nicotine dependence, cigarettes, uncomplicated Current smoker. Documents ongoing tobacco use alongside the nodule finding.
J84.09 Other alveolar and parieto-alveolar conditions Interstitial lung abnormalities seen alongside nodules on screening CT.

Diagnosis code selection should reflect the documented clinical indication for the analysis. R91.1 (solitary pulmonary nodule) is the most commonly paired code. Multiple diagnosis codes may be submitted on the same claim when clinically appropriate. Always follow your institution's coding guidelines and payer-specific requirements.

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Billing Mechanics

How Providers Bill and Get Paid

A practical guide to claim submission for quantitative CT tissue characterization under CPT 0721T and +0722T. These billing workflows are available today for FDA-cleared products.

Hospital Outpatient Setting

Facility Billing

Hospitals and hospital-based imaging centers bill 0721T or +0722T on the UB-04 (CMS-1450) institutional claim form. The facility receives the APC base payment of $650.50 (before wage index adjustment). A CT revenue code, typically 0352 (CT Body) or 0359 (CT Other), is appropriate; confirm with your chargemaster and payers.

Physician Component

The interpreting radiologist or pulmonologist bills a separate professional claim (CMS-1500) for the interpretation. Professional payment rates vary by locality and are set in the Medicare Physician Fee Schedule.

Freestanding Imaging Center

Global Billing

Freestanding radiology practices may bill the global service (technical + professional) on a single CMS-1500 claim, or split it with modifiers 26 and TC. Outside the hospital setting, payment is set by the local Medicare contractor (contractor priced), not the OPPS rate.

Place of Service

Use Place of Service 22 (On Campus-Outpatient Hospital) for hospital settings, or 11 (Office) / 15 (Mobile Unit) for freestanding locations. POS affects the Medicare payment rate applied.

Claim Submission Checklist

  • Verify the product used holds FDA clearance for quantitative CT tissue characterization
  • Document clinical indication and supporting ICD-10-CM diagnosis code (e.g., R91.1)
  • Confirm the analysis was ordered by a qualified physician
  • Include the interpreting physician's report in the medical record
  • Submit CPT 0721T (standalone) or +0722T (with concurrent CT, alongside primary CT code)
  • Do not bill both 0721T and +0722T for the same patient encounter
  • Apply appropriate modifiers (26 for professional component, TC for technical, if split billing)
  • Check your MAC's local coverage determination for any additional documentation requirements

Get this checklist as a printable PDF sent straight to your inbox.

Ready to Bring Reimbursable AI
to Your Lung Screening Program?

Learn how Oatmeal Health is building LungAI to fit within the existing Medicare reimbursement pathway for quantitative CT tissue characterization.

LungAI is an investigational medical device under development by Oatmeal Health. It is not FDA 510(k) cleared, is not available for clinical use, and does not replace physician judgment. Billing under CPT 0721T will be available following FDA 510(k) clearance.