CMS modified NCD 162 governing HIS Bundle Study coverage, effective March 7, 2026. Here's what billing teams need to know.
The Centers for Medicare & Medicaid Services updated NCD 162, the National Coverage Determination governing the HIS Bundle Study — a specialized electrocardiographic procedure requiring right heart catheterization. This coverage policy sets strict patient selection criteria and includes two important bundling rules that directly affect how you bill when the HIS Bundle Study is performed alongside other cardiac procedures. The policy does not list specific CPT or HCPCS codes, so your billing team will need to verify applicable codes with your Medicare Administrative Contractor.
Quick-Reference Table
| Field | Detail |
|---|---|
| Payer | CMS (Centers for Medicare & Medicaid Services) |
| Policy | HIS Bundle Study — NCD 162 |
| Policy Code | NCD 162 |
| Change Type | Modified |
| Effective Date | 2026-03-07 |
| Impact Level | Medium — affects cardiac electrophysiology billing when procedures are combined |
| Specialties Affected | Cardiology, Cardiac Electrophysiology, Interventional Cardiology |
| Key Action | Audit your charge capture for cases where HIS Bundle Studies are billed alongside heart catheterization or diagnostic endocardial electrical stimulation |
CMS HIS Bundle Study Coverage Criteria and Medical Necessity Requirements 2026
CMS covers the HIS Bundle Study under a narrow set of medical necessity criteria. The coverage policy limits reimbursement to three specific patient populations. Billing outside these groups will result in claim denial.
The three covered patient groups are:
| # | Covered Indication |
|---|---|
| 1 | Patients with complex ongoing acute arrhythmias |
| 2 | Patients with intermittent or permanent heart block where pacemaker implantation is being considered |
| 3 | Patients who recently developed heart block secondary to a myocardial infarction |
If your patient does not fit one of these three categories, Medicare will not cover the HIS Bundle Study. Document the qualifying indication explicitly in the medical record before the claim goes out. Vague documentation like "cardiac workup" will not support medical necessity under this policy.
This is a diagnostic procedure, classified under Medicare's Diagnostic Tests (Other) benefit category. That classification matters for prior authorization purposes — some Medicare Advantage plans layer their own prior authorization requirements on top of NCD criteria, so check plan-level rules before scheduling.
The real issue here is specificity. CMS coverage policy for the HIS Bundle Study is not ambiguous about who qualifies. The three indications are narrow and clearly defined. Your documentation has to match them exactly. If your physicians are documenting in general terms, that's your highest-risk exposure point under this policy.
CMS HIS Bundle Study Exclusions and Non-Covered Indications
The policy does not use language like "experimental" or "investigational," but it draws two hard lines on bundling that function as non-coverage rules in practice.
Bundling Rule 1 — Heart Catheterization Performed at the Same Time:
When heart catheterization and the HIS Bundle Study are performed during the same session, Medicare covers only one catheterization. It will allow a small additional charge for the study itself — but not a full separate charge for a second catheterization.
This is a common billing error in cardiology. A physician performs a right heart cath and a HIS Bundle Study in the same encounter. The billing team submits charges for both procedures as if they are fully independent. Medicare processes the claim, pays for one catheterization plus the add-on charge, and denies the rest. If your charge capture doesn't flag this combination, you will see systematic underpayments or denials on these cases.
Bundling Rule 2 — HIS Bundle Cardiogram as Part of Endocardial Electrical Stimulation:
When a HIS bundle cardiogram is obtained as part of a diagnostic endocardial electrical stimulation study, no separate charge for the HIS Bundle Study is recognized. Zero. The cardiogram is considered included in the stimulation study.
This is the more financially significant rule. Diagnostic endocardial electrical stimulation carries its own reimbursement, and if your team is also submitting a separate line for the HIS Bundle Study in that context, those claims are being overbilled. Pull a sample of your electrophysiology claims and check now.
Coverage Indications at a Glance
| Indication | Status | Relevant Codes | Notes |
|---|---|---|---|
| Complex ongoing acute arrhythmias | Covered | No specific codes listed in NCD 162 | Medical necessity documentation required |
| Intermittent or permanent heart block — pacemaker implantation being considered | Covered | No specific codes listed in NCD 162 | Must document pacemaker consideration explicitly |
| Heart block secondary to recent myocardial infarction | Covered | No specific codes listed in NCD 162 | Timing of "recently developed" should be documented |
| HIS Bundle Study performed with simultaneous heart catheterization | Partial — one catheterization covered plus small add-on charge | No specific codes listed in NCD 162 | Do not bill full charge for second catheterization |
| HIS bundle cardiogram obtained as part of diagnostic endocardial electrical stimulation | Not separately covered | No specific codes listed in NCD 162 | Considered included in stimulation study — no separate charge |
| All other indications | Not Covered | — | Outside NCD 162 coverage criteria |
CMS HIS Bundle Study Billing Guidelines and Action Items 2026
These are direct actions your billing team should take before or immediately after the effective date of March 7, 2026.
| # | Action Item |
|---|---|
| 1 | Audit your charge capture rules for cardiac electrophysiology encounters. Pull every case in the last 90 days where a HIS Bundle Study was billed alongside a right heart catheterization or a diagnostic endocardial electrical stimulation. Check whether both were billed as fully independent charges. If they were, you likely have overpayments or pending denials to address. |
| 2 | Update your charge capture workflow to flag these two procedure combinations. Your billing system should alert coders when a HIS Bundle Study appears on the same claim as a heart catheterization or an endocardial electrical stimulation study. Without that flag, the error recurs every time. |
| 3 | Confirm the applicable CPT codes with your Medicare Administrative Contractor. NCD 162 does not list specific CPT or HCPCS codes. Your MAC's local coverage determination or billing guidelines may specify the exact codes recognized for the HIS Bundle Study and related procedures. Contact your MAC before the effective date of March 7, 2026 to confirm. |
| 4 | Tighten your medical necessity documentation standards with your cardiology and electrophysiology physicians. The claim has to tie directly to one of three covered indications. Build a documentation template or checklist that prompts physicians to document which qualifying criterion applies — acute arrhythmia, heart block with pacemaker consideration, or post-MI heart block. |
| 5 | Check Medicare Advantage plan requirements separately. NCD 162 sets the Medicare fee-for-service floor. Medicare Advantage plans may have different or additional prior authorization requirements for HIS Bundle Studies. HIS Bundle Study billing under MA plans needs its own review — don't assume NCD criteria are sufficient. |
| 6 | If you're not sure how the bundling rules apply to your specific procedure mix, loop in your compliance officer before March 7, 2026. The partial coverage rule for simultaneous catheterization — one cath plus a small add-on — is easy to misapply if your coders aren't clear on what "small additional charge" means in your MAC's fee schedule. That's a compliance risk, not just a billing question. |
| 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 HIS Bundle Study Under NCD 162
Applicable Codes
The Centers for Medicare & Medicaid Services did not list specific CPT, HCPCS, or ICD-10 codes within NCD 162. This is a meaningful gap for HIS Bundle Study billing. Your MAC is the authoritative source for which codes apply in your region.
| Code Type | Status | Guidance |
|---|---|---|
| CPT | Not specified in NCD 162 | Contact your Medicare Administrative Contractor to confirm accepted procedure codes |
| HCPCS | Not specified in NCD 162 | Contact your Medicare Administrative Contractor to confirm accepted codes |
| ICD-10-CM | Not specified in NCD 162 | Diagnosis codes should reflect the qualifying indication — acute arrhythmia, heart block (intermittent, permanent, or post-MI) |
What this means for your team: The absence of listed codes does not mean the procedure lacks billable codes. It means CMS has left code-level specificity to the MAC level. HIS Bundle Study billing requires you to work from your MAC's local guidance, not just the NCD.
Cross-reference NCD 162 with NCD Manual Section 20.12, which CMS cites directly in this policy. That section may provide additional procedure-level detail relevant to code selection.
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