TL;DR: The Centers for Medicare & Medicaid Services modified NCD 164 governing thermography, effective March 7, 2026, reaffirming a blanket exclusion from Medicare coverage for all indications. No CPT or HCPCS codes are listed in the policy — and that tells you something about how CMS views this service entirely.
CMS, the Centers for Medicare & Medicaid Services, updated NCD 164 — the National Coverage Determination governing thermography — with a March 7, 2026 effective date. The policy maintains the long-standing position that thermography is non-covered for every clinical indication under Medicare, including breast lesion evaluation, which was explicitly excluded as far back as July 20, 1984. If your billing team submits thermography claims to Medicare, expect denial. Every time.
Quick-Reference Table
| Field | Detail |
|---|---|
| Payer | CMS (Centers for Medicare & Medicaid Services) |
| Policy | Thermography |
| Policy Code | NCD 164 |
| Change Type | Modified |
| Effective Date | 2026-03-07 |
| Impact Level | Low (reaffirms existing non-coverage — but high exposure if your team has been billing this) |
| Specialties Affected | Radiology, Breast Imaging, Diagnostic Imaging, Integrative Medicine |
| Key Action | Audit your charge master and superbill for any thermography line items and remove or flag them as non-covered before March 7, 2026 |
CMS Thermography Coverage Criteria and Medical Necessity Requirements 2026
There are no coverage criteria for thermography under Medicare. That's not an oversimplification — that's exactly what NCD 164 says.
CMS has determined that thermography, the measurement of self-emanating infrared radiation used to reveal temperature variations at the body's surface, does not meet medical necessity standards for any clinical indication. The agency's position, published as a Final Notice in the Federal Register on November 20, 1992, is that the available evidence does not support thermography as a useful aid in the diagnosis or treatment of illness or injury. CMS uses the phrase "not considered effective" — and in Medicare billing terms, that phrase ends the conversation.
There is no prior authorization pathway for thermography under Medicare because there's nothing to authorize. Prior auth exists for covered services with utilization controls. When a service is categorically excluded from coverage, prior auth is irrelevant — the claim denies regardless.
No reimbursement is available under Medicare for thermography under any circumstance. It doesn't matter what the clinical rationale is, what the ordering physician documented, or how compelling the patient's presentation. The CMS coverage policy here is absolute, and it has been since 1992.
CMS Thermography Exclusions and Non-Covered Indications
CMS excludes thermography across the board — not just for specific use cases, but universally. Two exclusions are worth calling out specifically because they come up in the field.
Breast lesion evaluation has been explicitly excluded since July 20, 1984. This predates the broader NCD 164 exclusion. Some practices in breast imaging or women's health have historically tried to position thermography as a supplemental screening tool alongside mammography, particularly for patients who decline mammograms or have dense breast tissue. CMS has been consistent: that argument doesn't hold. Thermography for breast lesions is not covered under Medicare, full stop.
All other indications fall under the 1992 Final Notice exclusion. The policy language says "for any indication" — that includes vascular assessment, musculoskeletal evaluation, pain management workups, thyroid imaging, and any other application where thermography might appear on a requisition. There's no carve-out, no exception pathway, and no Medicare Advantage plan rider that restores coverage (though you should verify plan-level benefits separately for MA, since MA plans set their own supplemental benefits).
The real issue here is that thermography has experienced a commercial revival in certain integrative and functional medicine settings. Practitioners promoting it as a non-radiation alternative to mammography or as a metabolic screening tool are generating patient demand — and some of those patients are Medicare beneficiaries. Your team needs to catch this before the claim goes out, not after it denies.
Coverage Indications at a Glance
| Indication | Status | Relevant Codes | Notes |
|---|---|---|---|
| Breast lesion evaluation | Not Covered | No codes listed in policy | Excluded from Medicare coverage since July 20, 1984 |
| All other clinical indications | Not Covered | No codes listed in policy | Excluded per CMS Final Notice, Federal Register, November 20, 1992 |
CMS Thermography Billing Guidelines and Action Items 2026
| # | Action Item |
|---|---|
| 1 | Audit your charge master before March 7, 2026. Search for any thermography line items — thermal imaging, infrared thermography, digital infrared thermal imaging (DITI), or similar descriptors. If any of those exist and your practice sees Medicare patients, flag them as non-covered and remove them from your standard charge capture workflow. |
| 2 | Update your superbill and EHR order sets. If thermography appears as an orderable item in your EHR, add a hard stop or warning for Medicare patients. The denial is guaranteed, and submitting it anyway generates unnecessary AR work, potential compliance exposure, and patient confusion about their liability. |
| 3 | Implement an Advance Beneficiary Notice (ABN) process if you plan to offer thermography to Medicare patients at all. If a Medicare patient requests thermography and you're willing to provide it, an ABN is required before service delivery to shift financial responsibility to the patient. Without a valid ABN, you can't bill the patient for a non-covered service. Make sure your front desk and clinical staff understand when an ABN is appropriate — and that it must be signed before the service, not after. |
| 4 | Verify Medicare Advantage plan benefits separately. NCD 164 governs traditional Medicare (Parts A and B). Medicare Advantage plans are not bound by NCDs in the same way — some MA plans have added supplemental benefits that cover services CMS excludes. Before assuming an MA patient's thermography claim will deny, check the specific plan's evidence of coverage. Don't assume CMS non-coverage automatically applies to every MA payer in your contracts. |
| 5 | Train your front desk on patient communication. Patients who request thermography — especially for breast screening — often arrive with strong opinions and may have been told by a provider elsewhere that it's a legitimate alternative to mammography. Your staff needs language to explain that Medicare does not cover this service and that the patient will bear the full cost if they choose to proceed. This conversation is easier before the appointment than after a denied claim. |
| 6 | If your practice has submitted thermography claims to Medicare recently and received payment, loop in your compliance officer immediately. NCD 164 has been in place since 1992. Any payments that came through represent potential overpayment liability. Self-disclosure timelines and processes matter here — don't wait. |
| 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 Thermography Under NCD 164
No Codes Listed in Policy
NCD 164 does not list specific CPT or HCPCS codes. This is notable — it means CMS has not assigned thermography a billable code structure within the Medicare system, which is itself a signal of how thoroughly this service is excluded from the program.
| Field | Detail |
|---|---|
| CPT Codes | None specified in NCD 164 |
| HCPCS Codes | None specified in NCD 164 |
| ICD-10-CM Codes | None specified in NCD 164 |
The absence of codes is not an oversight or gap you can work around. It reflects the policy position: there is no covered version of this service under Medicare, so there's no code set to reference. If you see thermography described with unlisted codes or miscategorized under adjacent imaging codes on claims, that's a billing accuracy problem — and potentially a compliance problem. Claims billed under mislabeled codes to get a thermography service paid represent a fraud risk, not a billing workaround.
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