TL;DR: The Centers for Medicare & Medicaid Services modified NCD 111 effective March 7, 2026, officially retiring the standalone gastric balloon coverage policy and redirecting all coverage authority to NCD 100.1. Here's what billing teams need to know before this trips up a claim.
The Centers for Medicare & Medicaid Services retired NCD 111 — the National Coverage Determination governing the CMS gastric balloon coverage policy — and folded it into NCD 100.1, effective September 24, 2013. The March 7, 2026 update makes this consolidation explicit in the NCD Manual. This policy does not list specific CPT or HCPCS codes. If your team has been referencing NCD 111 directly for gastric balloon billing, you're citing a dead document.
Quick-Reference Table
| Field | Detail |
|---|---|
| Payer | CMS / Medicare |
| Policy | Gastric Balloon for Treatment of Obesity — RETIRED |
| Policy Code | NCD 111 |
| Change Type | Modified (Retirement confirmed) |
| Effective Date | 2026-03-07 |
| Impact Level | Medium |
| Specialties Affected | Bariatric surgery, gastroenterology, general surgery |
| Key Action | Stop referencing NCD 111 directly — update all internal policy citations and billing guidelines to NCD 100.1 |
CMS Gastric Balloon Coverage Criteria and Medical Necessity Requirements 2026
The real issue here is one of documentation hygiene, not clinical coverage. NCD 111 no longer exists as a standalone section in the NCD Manual. Section 100.11 was removed and absorbed into NCD 100.1 back in 2013. The March 2026 update is CMS formally codifying that retirement in the published revision history.
What this means for your billing team: any internal coverage policy, payer grid, or prior authorization checklist that cites "NCD 111" as the authority for gastric balloon services is out of date. If a claim denial comes back citing incorrect policy references, that's on your documentation — not on CMS.
Medical necessity criteria for gastric balloon procedures now live exclusively under NCD 100.1. Pull that document and confirm your team is applying the correct coverage policy criteria. Prior authorization requirements, if applicable at the local level, will also flow from that NCD and any related local coverage determinations your Medicare Administrative Contractor has issued.
One more thing: because NCD 100.1 is the governing document, your medical necessity arguments on appeal need to cite NCD 100.1 — not NCD 111. Citing a retired section in a redetermination request is a red flag for any reviewer. Fix this before it costs you on appeal.
CMS Gastric Balloon Exclusions and Non-Covered Indications
NCD 111 itself does not list exclusions. The policy has been retired entirely. There are no standalone coverage criteria, non-covered indications, or experimental designations within NCD 111 to interpret.
Any exclusion or non-coverage determination for gastric balloon procedures now derives from NCD 100.1. That's where you'll find the operative language on what Medicare does and does not cover for obesity treatment interventions, including the gastric balloon.
If you're managing a claim denial based on medical necessity for a gastric balloon service, NCD 100.1 is the document your team needs in hand — not this one.
Coverage Indications at a Glance
| Indication | Status | Relevant Codes | Notes |
|---|---|---|---|
| Gastric balloon for obesity treatment | Governed by NCD 100.1 | No codes listed in NCD 111 | NCD 111 retired; all coverage authority moved to NCD 100.1 effective 9/24/2013 |
| Any indication previously under NCD 111 | Refer to NCD 100.1 | No codes listed in NCD 111 | Citing NCD 111 on claims or appeals is no longer valid |
CMS Gastric Balloon Billing Guidelines and Action Items 2026
These are the steps your billing team needs to take now. The effective date of March 7, 2026 is already past — treat this as urgent cleanup.
| # | Action Item |
|---|---|
| 1 | Audit your internal policy documents. Search for any reference to "NCD 111" in your charge capture workflows, billing guidelines, payer grids, or prior authorization checklists. Every instance needs to be updated to NCD 100.1 before your next gastric balloon claim goes out. |
| 2 | Pull NCD 100.1 and review current coverage criteria. NCD 100.1 is the governing document for gastric balloon reimbursement decisions under Medicare. Make sure your billing team and clinical documentation staff are working from the correct medical necessity criteria. |
| 3 | Check your MAC's local coverage determinations. Your Medicare Administrative Contractor may have issued an LCD that supplements NCD 100.1 for obesity-related procedures. Search your MAC's website for any applicable LCD. Local coverage determination policies can tighten or clarify what NCD 100.1 allows, and your team needs to know both. |
| 4 | Update your denial management workflows. If a claim denial comes back on a gastric balloon service, your appeal needs to cite NCD 100.1 — not NCD 111. Audit your appeal templates now. A redetermination request that cites a retired NCD section undermines your credibility with the reviewer. |
| 5 | Confirm prior authorization requirements at the local level. NCD 111 does not address prior authorization. Your MAC's LCD or your specific plan contract may impose prior auth requirements for gastric balloon procedures. Verify this under NCD 100.1 and any applicable LCD before scheduling or billing. |
| 6 | Brief your coding and clinical staff. Coders and physicians who document for gastric balloon procedures need to know that coverage policy authority has shifted. The clinical record needs to support medical necessity under NCD 100.1 — not the retired standard. |
If you're uncertain how NCD 100.1 applies to your specific patient mix or procedure volume, loop in your compliance officer before your next billing cycle.
| 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 Gastric Balloon Under NCD 111
Covered CPT Codes
This policy does not list specific codes. NCD 111 has been retired and contains no applicable CPT or HCPCS codes. All code-level coverage guidance for gastric balloon billing now falls under NCD 100.1.
Not Covered / Experimental Codes
No codes are listed in this policy. NCD 111 has no active coding guidance. Do not use this NCD as a source for code-level billing decisions.
Key ICD-10-CM Diagnosis Codes
No ICD-10-CM codes are listed in NCD 111. Reference NCD 100.1 and your MAC's LCD for applicable diagnosis codes that support medical necessity for gastric balloon procedures under Medicare.
A Note on Why This Policy Change Still Matters
You might look at this and think: "This is just a housekeeping update. NCD 111 has been retired since 2013. Why does a 2026 revision matter?"
Here's why it matters. Stale policy references are one of the most common — and most avoidable — reasons that appeal letters get dismissed. If your team has been working from legacy payer grids or billing guidelines that were built before 2013, NCD 111 might still be in your documentation stack. The March 7, 2026 revision is CMS putting a formal timestamp on this retirement. That gives you a concrete moment to trigger an internal audit.
It's also a signal. When CMS formally closes out an NCD, it sometimes precedes a broader coverage policy review or update in the consolidated NCD. Watch NCD 100.1 for changes in the coming months. If CMS is cleaning house on the NCD Manual, related sections may see updates too.
This is the same pattern you see when payers consolidate clinical policy bulletins — administrative tidying that creates real claim risk when billing teams don't update their internal documentation to match.
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