CMS modified NCD 116 for laparoscopic cholecystectomy, effective March 7, 2026. Here's what billing teams need to know.
The Centers for Medicare & Medicaid Services updated NCD 116, the National Coverage Determination governing Medicare coverage of laparoscopic cholecystectomy. This modification confirms covered billing for gallbladder removal using laparoscopic technique — including procedures performed with cholangiography. The policy does not list specific CPT codes by number, but it references two distinct CPT code categories your team must use correctly depending on the procedure performed.
Quick-Reference Table
| Field | Detail |
|---|---|
| Payer | CMS / Medicare |
| Policy | Laparoscopic Cholecystectomy — NCD 116 |
| Policy Code | NCD 116 |
| Change Type | Modified |
| Effective Date | 2026-03-07 |
| Impact Level | Medium |
| Specialties Affected | General Surgery, Inpatient Hospital Billing, Outpatient Hospital Billing, Physician Billing |
| Key Action | Confirm your team uses the correct CPT code category based on whether cholangiography was performed — standard cholecystectomy vs. cholecystectomy with cholangiography |
CMS Laparoscopic Cholecystectomy Coverage Criteria and Medical Necessity Requirements 2026
CMS laparoscopic cholecystectomy coverage policy under NCD 116 defines this as a covered surgical procedure. The patient must have a diseased gallbladder. The surgery is performed using instruments introduced through cannulae, with the operative field visualized via a high-resolution television camera-monitor system — what the policy calls a video laparoscope.
That clinical definition matters for medical necessity documentation. Your operative notes need to reflect that the procedure was performed laparoscopically with video visualization. A claim for laparoscopic cholecystectomy that lacks documentation supporting the laparoscopic approach creates a medical necessity gap — and that gap is a direct path to claim denial.
The coverage policy applies across three Medicare benefit categories: inpatient hospital services, outpatient hospital services incident to a physician's service, and physicians' services. That breadth means billing teams across inpatient, outpatient, and professional fee settings are all affected by this update.
Prior Authorization Under NCD 116
NCD 116 does not specify a prior authorization requirement for laparoscopic cholecystectomy. That said, your Medicare Administrative Contractor may impose additional requirements at the local level. Check with your MAC before assuming blanket approval — some local coverage determinations layer requirements on top of NCDs. If you're unsure how your MAC's LCD interacts with this NCD, ask your compliance officer before billing.
Inpatient vs. Outpatient: Different Reporting Rules
This is where NCD 116 gets specific, and where billing errors are most likely to happen.
For inpatient claims, the policy instructs you to report the diagnosis code for laparoscopic cholecystectomy. It does not say "CPT code" — it says "diagnosis code." That matters. Inpatient hospital claims under Medicare Part A use ICD-10-PCS procedure codes alongside diagnosis coding, not CPT. Your inpatient coders need to know this distinction.
For all other claims — outpatient hospital and physician billing — the policy directs you to report the appropriate CPT code. Two separate CPT code categories apply here:
| # | Covered Indication |
|---|---|
| 1 | Laparoscopy, surgical; cholecystectomy (any method) — use this when the procedure does not include cholangiography |
| 2 | Laparoscopy, surgical: cholecystectomy with cholangiography — use this when the surgeon also performs intraoperative cholangiography |
The policy does not list specific CPT code numbers. You must confirm the current correct CPT codes for these two descriptions with your coding team or CPT codebook. Using the wrong category — billing the standard cholecystectomy code when cholangiography was performed — misrepresents the procedure and affects reimbursement. It also creates audit exposure.
Coverage Indications at a Glance
| Indication | Status | Relevant Codes | Notes |
|---|---|---|---|
| Laparoscopic removal of diseased gallbladder using cannulae and video laparoscope | Covered | Appropriate CPT for laparoscopy, surgical; cholecystectomy (any method) | Outpatient and physician claims only — use CPT |
| Laparoscopic cholecystectomy with intraoperative cholangiography | Covered | Appropriate CPT for laparoscopy, surgical: cholecystectomy with cholangiography | Report separately from standard cholecystectomy code |
| Laparoscopic cholecystectomy — inpatient hospital | Covered | Diagnosis code for laparoscopic cholecystectomy (ICD-10-PCS on inpatient claims) | Do NOT use CPT on Part A inpatient claims |
CMS Laparoscopic Cholecystectomy Billing Guidelines and Action Items 2026
The effective date of March 7, 2026 means this policy is already active. If your team hasn't reviewed charge capture and documentation workflows against NCD 116, do it now.
| # | Action Item |
|---|---|
| 1 | Audit your outpatient and physician fee schedule charge capture. Confirm you have two distinct charge codes mapped — one for standard laparoscopic cholecystectomy and one for laparoscopic cholecystectomy with cholangiography. These are separate CPT categories and must be billed separately. Conflating them is a reimbursement error. |
| 2 | Brief your inpatient coders on the diagnosis code requirement. The policy explicitly separates inpatient reporting from outpatient CPT reporting. Inpatient claims go through ICD-10-PCS coding, not CPT. Make sure your inpatient team isn't defaulting to a CPT-based workflow for Part A claims on this procedure. |
| 3 | Review operative note templates with your surgeons. Documentation must support the laparoscopic approach — cannulae use and video laparoscope visualization. If a surgeon converts to open cholecystectomy mid-procedure, your coding team needs a clear protocol for how to handle that claim. NCD 116 covers the laparoscopic procedure specifically. |
| 4 | Check with your MAC for any local coverage determination that overlays this NCD. NCD 116 sets national coverage, but your MAC can add requirements. A claim that satisfies NCD 116 medical necessity criteria can still be denied if your MAC has additional LCD requirements your team isn't meeting. |
| 5 | Verify cholangiography documentation when billing the with-cholangiography CPT category. If you bill laparoscopic cholecystectomy with cholangiography, the operative report must document that cholangiography was performed. Billing the more complex code without supporting documentation is a claim denial waiting to happen — and a compliance issue. |
| 6 | Pull a 90-day lookback on laparoscopic cholecystectomy claims. Compare how your team has been coding against what NCD 116 now explicitly requires. If you find inconsistency between cholangiography billing and operative documentation, correct it proactively. Talk to your compliance officer about whether a self-disclosure is warranted. |
The real issue here is the inpatient vs. outpatient split. Most billing errors on this procedure will come from teams applying CPT logic to inpatient claims or failing to distinguish the cholangiography code category from the standard code. Both errors affect reimbursement directly — and both are avoidable with the right charge capture setup.
| 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 Laparoscopic Cholecystectomy Under NCD 116
NCD 116 does not list specific CPT or HCPCS codes by number. The policy references two CPT code categories by description only. Confirm the current code numbers with your CPT codebook or coding team.
CPT Code Categories Referenced by NCD 116
| Category | Type | Description | Claim Setting |
|---|---|---|---|
| Not specified by number | CPT | Laparoscopy, surgical; cholecystectomy (any method) | Outpatient hospital and physician claims |
| Not specified by number | CPT | Laparoscopy, surgical: cholecystectomy with cholangiography | Outpatient hospital and physician claims |
Inpatient Coding Note
| Code Type | Description | Claim Setting |
|---|---|---|
| ICD-10-PCS (not specified by NCD) | Diagnosis code for laparoscopic cholecystectomy | Inpatient hospital (Part A) claims only |
NCD 116 instructs inpatient billers to use the diagnosis code — not CPT — for inpatient laparoscopic cholecystectomy claims. Your inpatient coding team should confirm the current ICD-10-PCS code for this procedure through your coding resources.
A note on the missing codes: The absence of specific code numbers in the NCD is a known limitation of older-format NCDs. CMS wrote NCD 116 by procedure description rather than by code. That puts the burden on your coding team to map the policy language to current CPT and ICD-10-PCS codes correctly. This is not unusual for legacy NCDs — but it does mean you can't just pull a code list from the policy document itself.
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