TL;DR: Aetna, a CVS Health company, modified CPB 0494 governing hematopoietic cell transplantation (HCT) for non-Hodgkin's lymphoma, with an effective date of December 11, 2025. Here's what changes for billing teams.
This update to the Aetna NHL transplant coverage policy touches CPT codes 38205, 38206, 38230, 38232, 38240, and 38241 — the core harvesting and transplantation procedure codes — along with HCPCS code S2150 and HLA typing codes 86813, 86817, and 86821. If your facility bills hematopoietic cell transplantation for NHL patients covered by Aetna, you need to review your medical necessity documentation and prior authorization workflows against the updated criteria now.
Quick-Reference Table
| Field | Detail |
|---|---|
| Payer | Aetna, a CVS Health company |
| Policy | Hematopoietic Cell Transplantation for Non-Hodgkin's Lymphoma |
| Policy Code | CPB 0494 |
| Change Type | Modified |
| Effective Date | December 11, 2025 |
| Impact Level | High |
| Specialties Affected | Hematology/Oncology, Bone Marrow Transplant Programs, Hospital Revenue Cycle |
| Key Action | Audit prior authorization submissions and medical necessity documentation against updated autologous and allogeneic HCT criteria before billing CPT 38240 or 38241 |
Aetna Hematopoietic Cell Transplantation Coverage Criteria and Medical Necessity Requirements 2025
CPB 0494 Aetna covers two distinct transplant pathways for NHL: autologous and allogeneic. The criteria differ meaningfully between the two. Mixing them up in a prior authorization request is a fast path to a claim denial.
Autologous HCT: What Aetna Requires
Aetna considers autologous HCT — billed under CPT 38206 (blood-derived progenitor cell harvesting, autologous) and CPT 38241 (autologous transplantation) — medically necessary for relapsed or primary refractory NHL when all three conditions are met:
| # | Covered Indication |
|---|---|
| 1 | The patient has relapsed or refractory NHL. |
| 2 | The disease is chemotherapy responsive, defined as at least a 50% decrease in tumor burden (complete or partial remission). |
| 3 | No serious organ dysfunction exists, based on the transplanting institution's evaluation. |
The definition of "responsive" matters here. Aetna defines responsiveness as a complete or partial remission. Partial remission means at least a 50% reduction in tumor burden. Document that number explicitly in your medical records. Don't leave the reviewer to infer it.
Refractory disease means failure to attain a complete or partial response. It can be primary (failure to respond to initial therapy) or secondary (initial response, then failure after relapse). The distinction matters for the chart documentation supporting your medical necessity criteria.
There's an exception on chemoresistant disease. Aetna will consider autologous HCT medically necessary for chemoresistant, widely metastatic relapsed disease if allogeneic transplantation can't be offered. This is a narrow carve-out. If you're billing for this scenario, your documentation needs to explicitly address why allogeneic transplant was ruled out.
Aetna also recognizes first clinical remission cases for specific high-risk subtypes. These include lymphoblastic NHL, Burkitt's lymphoma, mediastinal B-cell lymphoma, mantle cell lymphoma, high-risk diffuse large B-cell lymphoma, and other NHLs associated with poor prognosis. Clinical review drives these decisions. Get that documentation tight before submitting prior auth.
Allogeneic HCT: Different Criteria, Same Scrutiny
Allogeneic HCT — billed under CPT 38205 (blood-derived progenitor cell harvesting, allogeneic) and CPT 38240 (allogeneic transplantation per donor) — carries its own medical necessity criteria. Aetna covers it for relapsed NHL, including post-autologous HCT relapse, and for primary refractory NHL across all grades (low, intermediate, high).
Three criteria must all be met in the absence of a protocol:
| # | Covered Indication |
|---|---|
| 1 | The patient has relapsed or refractory NHL. |
| 2 | The patient has an appropriate donor: haploidentical to fully HLA-matched related donor, a well-matched unrelated donor meeting National Marrow Donor Program (NMDP) criteria, or single or double cord blood matched for at least 4 of 6 HLA ABDR antigens. |
| 3 | No serious organ dysfunction, per the transplanting institution's evaluation. |
HLA typing codes 86813 (HLA typing, A, B, or C, multiple antigens), 86817 (DR/DQ, multiple antigens), and 86821 (lymphocyte culture, mixed) are covered when selection criteria are met. These codes support the donor matching requirement. Don't bill them in isolation — they need to connect to the allogeneic transplant authorization.
Aetna also covers non-myeloablative allogeneic HCT ("mini-transplant," reduced intensity conditioning transplant) under this policy. The reimbursement pathway and documentation requirements follow the same allogeneic criteria. First clinical remission cases are also considered for lymphoblastic NHL, Burkitt's, mediastinal B-cell lymphoma, mantle cell lymphoma, and other poor-prognosis NHLs.
This is a complex policy with a lot of moving parts. If your transplant program doesn't have a dedicated billing specialist who works these cases daily, talk to your compliance officer before the December 11 effective date.
Aetna HCT for NHL Exclusions and Non-Covered Indications
Aetna considers autologous HCT experimental, investigational, or unproven when specific contraindications are present. Two contraindications apply:
| # | Excluded Procedure |
|---|---|
| 1 | Co-morbid diseases — the policy cites uncontrolled hypertension as an example. |
| 2 | Evidence of serious organ dysfunction. |
These aren't soft guidelines. If the transplanting institution's evaluation documents serious organ dysfunction, Aetna will not cover autologous HCT under CPT 38241. A claim submitted without addressing these contraindications will be denied.
The real issue here is documentation. Organ dysfunction is flagged at the institution level, and Aetna defers to that evaluation. Your authorization package needs to clearly show the institution's findings — not just a checkbox, but actual clinical data.
Coverage Indications at a Glance
| Indication | Status | Relevant Codes | Notes |
|---|---|---|---|
| Autologous HCT — relapsed or refractory NHL, chemotherapy responsive, no serious organ dysfunction | Covered | 38206, 38241, S2150 | All three criteria must be met; prior authorization required |
| Autologous HCT — first clinical remission, high-risk subtypes (lymphoblastic NHL, Burkitt's, MCL, DLBCL, mediastinal B-cell) | Covered (clinical review) | 38206, 38241 | Subject to clinical review; document poor prognosis indicators |
| Autologous HCT — chemoresistant, widely metastatic relapsed disease where allogeneic can't be offered | Covered (medical review) | 38206, 38241 | Narrow exception; document why allogeneic is not available |
| Autologous HCT — co-morbid diseases (e.g., uncontrolled hypertension) | Experimental/Not Covered | 38206, 38241 | Claims will be denied; document absence of listed contraindications |
| Autologous HCT — serious organ dysfunction | Experimental/Not Covered | 38206, 38241 | Institution's evaluation is determinative |
| Allogeneic HCT — relapsed or refractory NHL (all grades), appropriate donor match, no organ dysfunction | Covered | 38205, 38240, S2150 | All three criteria must be met; NMDP donor criteria apply |
| Allogeneic HCT — post-autologous HCT relapse | Covered | 38205, 38240 | Explicitly included in policy language |
| Allogeneic HCT — first clinical remission, high-risk subtypes | Covered (clinical review) | 38205, 38240 | Subject to clinical review |
| Non-myeloablative allogeneic HCT (mini-transplant / RIC) | Covered | 38205, 38240 | Follows same allogeneic criteria |
| HLA typing for donor matching | Covered (with allogeneic HCT criteria) | 86813, 86817, 86821 | Must link to allogeneic HCT authorization |
| Bone marrow harvesting — allogeneic | Covered (with criteria) | 38230 | Covered when selection criteria are met |
| Bone marrow harvesting — autologous | Covered (with criteria) | 38232 | Covered when selection criteria are met |
Aetna Hematopoietic Cell Transplantation Billing Guidelines and Action Items 2025
These are your specific action items before and after the December 11, 2025 effective date.
| # | Action Item |
|---|---|
| 1 | Pull your open prior authorization requests for CPT 38240 and 38241 now. Any authorization pending or expiring after December 11 should be re-checked against the updated CPB 0494 criteria. Don't assume a prior approval from earlier in 2025 reflects the current standards. |
| 2 | Update your medical necessity documentation templates. Your autologous HCT documentation needs to explicitly address all three criteria: relapsed/refractory status, chemotherapy responsiveness with quantified tumor burden reduction (50% minimum), and organ dysfunction assessment from the transplanting institution. Missing any one of these will generate a claim denial. |
| 3 | Separate autologous and allogeneic authorization workflows. These are different pathways with different criteria. If your team uses a single template for both, split them. The donor matching requirement for allogeneic HCT — haploidentical, fully HLA-matched related, NMDP-compliant unrelated, or cord blood matched at 4 of 6 HLA ABDR antigens — has no analog in the autologous path. |
| 4 | Verify HLA typing billing links to allogeneic authorization. When you bill CPT 86813, 86817, or 86821, connect those claims to the allogeneic HCT case. These codes are covered when selection criteria are met — meaning the criteria for the transplant itself, not independently. |
| 5 | Document first-remission cases with specificity. If you're billing for a first-remission patient with mantle cell lymphoma, Burkitt's, or another listed high-risk subtype, the chart needs to make the poor-prognosis designation explicit. "High-risk" is not self-evident to a reviewer. Name the subtype, reference the criteria, and note that clinical review was the pathway. |
| 6 | Flag chemoresistant autologous HCT cases for compliance review. The exception for chemoresistant, widely metastatic, relapsed disease is real — but narrow. Your documentation must show why allogeneic transplant wasn't available. Talk to your compliance officer before submitting these claims. This one has denial risk if the documentation doesn't hold up. |
| 7 | Check your charge capture for CPT 38204, 38207–38215. These bone marrow and stem cell service codes appear in the policy as "other codes related to the CPB." They're not in the covered-with-criteria group, but they're referenced. Make sure your charge capture team understands how these relate to the core transplant codes and doesn't bill them in isolation expecting coverage. |
| Previous Version | Current Version |
|---|---|
| Coverage is considered experimental and investigational for all indications | Coverage is considered medically necessary when specific criteria are met |
| Prior authorization is not required | Prior authorization is required for initial treatment |
| Documentation must include clinical history | Documentation must include clinical history |
| Re-review every 24 months | Re-review every 12 months with updated clinical documentation |
CPT, HCPCS, and ICD-10 Codes for Hematopoietic Cell Transplantation Under CPB 0494
Covered CPT Codes (When Selection Criteria Are Met)
| Code | Type | Description |
|---|---|---|
| 38205 | CPT | Blood-derived hematopoietic progenitor cell harvesting for transplantation, per collection; allogeneic |
| 38206 | CPT | Blood-derived hematopoietic progenitor cell harvesting for transplantation, per collection; autologous |
| 38230 | CPT | Bone marrow harvesting for transplantation; allogeneic |
| 38232 | CPT | Bone marrow harvesting for transplantation; autologous |
| 38240 | CPT | Hematopoietic progenitor cell (HPC); allogeneic transplantation per donor |
| 38241 | CPT | Hematopoietic progenitor cell (HPC); autologous transplantation |
| 86813 | CPT | HLA typing; A, B or C multiple antigens |
| 86817 | CPT | HLA typing; DR/DQ, multiple antigens |
| 86821 | CPT | HLA typing; lymphocyte culture, mixed (MLC) |
Covered HCPCS Codes (When Selection Criteria Are Met)
| Code | Type | Description |
|---|---|---|
| S2150 | HCPCS | Bone marrow or blood-derived stem cells (peripheral or umbilical), allogeneic or autologous, harvesting, transplantation, and related complications |
Other CPT Codes Related to CPB 0494
These codes are referenced in the policy but are not listed in the covered-with-criteria group. Verify coverage and billing guidelines on a case-by-case basis.
| Code | Type | Description |
|---|---|---|
| 38204 | CPT | Bone Marrow or Stem Cell Services/Procedures |
| 38207 | CPT | Bone Marrow or Stem Cell Services/Procedures |
| 38208 | CPT | Bone Marrow or Stem Cell Services/Procedures |
| 38209 | CPT | Bone Marrow or Stem Cell Services/Procedures |
| 38210 | CPT | Bone Marrow or Stem Cell Services/Procedures |
| 38211 | CPT | Bone Marrow or Stem Cell Services/Procedures |
| 38212 | CPT | Bone Marrow or Stem Cell Services/Procedures |
| 38213 | CPT | Bone Marrow or Stem Cell Services/Procedures |
| 38214 | CPT | Bone Marrow or Stem Cell Services/Procedures |
| 38215 | CPT | Bone Marrow or Stem Cell Services/Procedures |
| 96401–96450 | CPT | Chemotherapy administration (full range) |
| Modifiers 4A–4Z | CPT | Histocompatibility/Blood Typing/Identity/Microsatellite |
Other HCPCS Codes Related to CPB 0494
| Code | Type | Description |
|---|---|---|
| Q0083 | HCPCS | Chemotherapy administration |
| Q0084 | HCPCS | Chemotherapy administration |
| Q0085 | HCPCS | Chemotherapy administration |
Key ICD-10-CM Diagnosis Codes
| Code Range | Description |
|---|---|
| C82.00–C96.9 | Malignant neoplasm of lymphoid, hematopoietic, and related tissue (excluding Hodgkin's disease) |
This ICD-10 range covers the full scope of NHL diagnoses applicable under this policy. Make sure your diagnosis codes link to the correct subtype within the range — specificity matters on these claims. A generic C85.90 (NHL, unspecified) when the record clearly supports a mantle cell lymphoma diagnosis (C83.10) leaves clinical nuance on the table and gives reviewers less to work with.
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