Washington, D.C. – The Medical Imaging & Technology Alliance (MITA) – the leading trade association representing manufacturers of medical imaging equipment, radiopharmaceuticals, contrast media, and focused ultrasound therapeutic devices – has submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the proposed notice for the Transitional Coverage for Emerging Technologies (TCET) program.

In its comments, MITA expressed its concerns about the scope and utility of the program as proposed. To ensure efficient market access for advanced imaging solutions and novel therapies, MITA recommended that CMS expand its criteria for TCET candidacy and grandfather products that would have been eligible for the previously proposed Medicare Coverage of Innovative Technology (MCIT) program but lost the opportunity to engage in that pathway when the MCIT program was rescinded.

MITA also raised that the TCET proposal, as written, does not align with other policy payment timeliness or adequately address ongoing coding and payment issues. Further, MITA advocated for the agency to expand the number of products handled by the TCET program given ongoing advances across the medical field.

“The TCET program is a modest step towards ensuring coverage of innovative products, but it’s essential that CMS expand criteria for eligible medical devices and equip the program to handle more products per year,” said Patrick Hope, Executive Director of MITA. “We look forward to working alongside CMS to implement efficient pathways from FDA authorization of a product to access for Medicare beneficiaries.”


The Medical Imaging & Technology Alliance (MITA), a division of NEMA, is the collective voice of medical imaging equipment manufacturers, innovators, and product developers. It represents companies whose sales comprise more than 90 percent of the global market for advanced medical imaging technology.