Anti-Inhibitor Coagulant Complex (AICC) — NCD 150 | CMS Coverage Update

CMS modified NCD 150 for anti-inhibitor coagulant complex (AICC), effective March 7, 2026. Here's what billing teams need to know.

The Centers for Medicare & Medicaid Services updated its coverage policy for AICC under National Coverage Determination 150. This drug treats hemophilia A patients with factor VIII inhibitor antibodies. The policy does not list specific HCPCS or CPT codes, so your billing team needs to confirm the correct drug codes through your MAC before submitting claims.

Quick-Reference Table

CMS Anti-Inhibitor Coagulant Complex Coverage Criteria and Medical Necessity Requirements 2026

NCD 150 is the National Coverage Determination governing Medicare coverage of AICC for hemophilia patients. CMS covers AICC under the Blood Clotting Factors for Hemophilia Patients benefit category. That benefit category matters for your billing team — it shapes how the claim routes and how reimbursement is calculated.

NCD 150 defines a single integrated coverage standard. Medicare covers AICC when it is furnished to patients who meet all of the following elements as described in the policy: the patient has hemophilia A with inhibitor antibodies to factor VIII, is experiencing major bleeding episodes, and has failed to respond to other, less expensive therapies. All elements must be present. A claim that can't be supported on every element is a denial waiting to happen.

Here's how each element plays out in billing:

That third element is where most billing problems start. If the chart just says "AICC administered" and the medical record doesn't reflect prior treatment failure, expect a denial on medical necessity grounds.

The coverage policy uses the phrase "safe and effective" to characterize AICC — which signals CMS is not treating this as experimental or investigational. That's good for billing teams. There's no coverage risk on the drug itself when the coverage standard is met. The risk is on the documentation side.

The policy does not explicitly state prior authorization requirements at the national level. Your Medicare Administrative Contractor may impose additional regional requirements. Check with your MAC before assuming clean submission. This is especially true for high-cost specialty drug claims.

CMS AICC Coverage Boundaries Under NCD 150

NCD 150 does not include a formal exclusion list. The policy defines coverage narrowly — patients who do not meet all elements of the coverage standard (hemophilia A, factor VIII inhibitors, major bleeding episodes, and prior therapy failure) would not meet coverage requirements under NCD 150.

That means a patient with hemophilia A and confirmed factor VIII inhibitor antibodies who has not yet failed less expensive therapies does not meet the full coverage standard. The step-therapy element is part of the criteria, not an afterthought. A provider who goes straight to AICC without documented prior treatment failure puts the claim at risk.

Similarly, patients with hemophilia B or other coagulation disorders fall outside the coverage standard as written. NCD 150 defines the covered population specifically. If the diagnosis doesn't match what the policy describes, the claim doesn't meet medical necessity under NCD 150.

The same logic applies to bleed severity. The policy requires major bleeding episodes. A patient who doesn't meet that threshold doesn't meet the full coverage standard — not because CMS explicitly lists minor bleeding as excluded, but because the covered indication requires major bleeding specifically.

Coverage Indications at a Glance

CMS Anti-Inhibitor Coagulant Complex Billing Guidelines and Action Items 2026

The modified NCD 150 is effective March 7, 2026. Here's what your billing team needs to do now.

The real issue with this policy is the gap between clinical practice and billing documentation. Physicians who treat hemophilia A know when AICC is appropriate. Getting that clinical judgment translated into clean, criteria-matching documentation is the billing challenge. Close that gap before March 7, 2026.

CPT, HCPCS, and ICD-10 Codes for Anti-Inhibitor Coagulant Complex Under NCD 150

The NCD 150 policy document does not list specific CPT, HCPCS, or ICD-10 codes. This is not unusual for older NCD policies — many predate the code-level specificity that newer coverage determinations include. It does create a real billing problem, though.

Your MAC is the authoritative source for which HCPCS codes to use when billing AICC to Medicare. HCPCS drug codes for AICC must be confirmed with your MAC directly. Do not rely on generic code lookups for this one. Get confirmation in writing if possible, or at minimum document the date and representative name from the call.

For ICD-10-CM diagnosis coding, confirm the correct diagnosis codes for hemophilia A with factor VIII inhibitors with your MAC and against current ICD-10-CM code sets for 2026. Your clinical documentation needs to support whatever code you bill — and that code needs to reflect both the hemophilia A diagnosis and the inhibitor status to map cleanly to the NCD 150 coverage criteria during a medical necessity review.

Because no codes are enumerated in this policy, the code table that typically appears here cannot be populated from the NCD 150 source document. Any codes used for AICC billing should be verified against your MAC's local coverage determination and current HCPCS and ICD-10 code sets for 2026.