CMS Thermography Coverage Policy 2026: NCD 164 Update for Billing Teams

TL;DR: The Centers for Medicare & Medicaid Services modified NCD 164 for thermography, effective March 7, 2026. Thermography remains fully excluded from Medicare coverage for all indications — including breast lesions. No reimbursement. No exceptions. Here's what your billing team needs to know.

This update to NCD 164 in the CMS Medicare system reaffirms a blanket non-coverage position that has been in place since 1992. Thermography billing under Medicare will trigger a claim denial regardless of the clinical indication. The policy lists no applicable CPT or HCPCS codes — because there are none to bill.

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Quick-Reference Table

Field	Detail Copy
Payer	CMS (Centers for Medicare & Medicaid Services)
Policy	Thermography — NCD 164
Policy Code	NCD 164
Change Type	Modified
Effective Date	2026-03-07
Impact Level	High — blanket exclusion, no covered pathway exists
Specialties Affected	Radiology, breast imaging, diagnostic imaging, oncology, primary care
Key Action	Remove thermography services from Medicare charge capture entirely and train front-desk staff to inform patients before service

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CMS Thermography Coverage Criteria and Medical Necessity Requirements 2026

The short answer: there are none. CMS has determined thermography does not meet medical necessity under any indication. That makes this coverage policy unusually simple to summarize — and unusually consequential to ignore.

NCD 164 defines thermography as the measurement of self-emanating infrared radiation to reveal temperature variations on the body surface. The device produces color-coded patterns, where each color represents a specific temperature level. Clinicians have historically used interpretation of these patterns to screen or diagnose a range of conditions.

CMS rejected that clinical case entirely. The agency published the exclusion as a Final Notice in the Federal Register on November 20, 1992. The effective date of March 7, 2026 represents a policy modification — but the non-coverage determination itself has not changed.

The basis for exclusion is straightforward: CMS concluded the available evidence does not support thermography as a useful aid in diagnosis or treatment of illness or injury. That language is significant. It means CMS is not calling this experimental or investigational — it's calling it ineffective. That's a harder position to appeal.

If your practice is wondering whether prior authorization could unlock coverage for a specific patient, stop there. Prior authorization is irrelevant when the service is categorically excluded. No prior auth pathway exists because there is no covered pathway at all.

This is the CMS thermography coverage policy in full: excluded, period, since 1992, reaffirmed in 2026.

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CMS Thermography Exclusions and Non-Covered Indications

Every single thermography indication is excluded. The policy does not carve out exceptions for specific diseases, high-risk patients, or clinical contexts.

The one specific callout worth flagging: breast lesion evaluation. CMS explicitly named breast thermography as excluded from Medicare coverage as of July 20, 1984 — years before the broader 1992 blanket exclusion. This matters because breast thermography has seen renewed marketing interest as an alternative to mammography, particularly in direct-to-consumer settings.

If a patient comes to you with a thermography order or request related to breast cancer screening, that service is not reimbursable under Medicare. Billing it anyway is not a gray area — it's a path to a claim denial and potential fraud exposure if you know the exclusion applies.

The real issue here is patient expectation management. Some patients will arrive having already seen thermography promoted as a screening tool. Your front desk and clinical staff need a consistent, clear response ready before that conversation happens.

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Coverage Indications at a Glance

Indication	Status	Relevant Codes	Notes Copy
Breast lesion evaluation	Not Covered	None listed	Excluded from Medicare coverage since July 20, 1984
All other thermography indications	Not Covered	None listed	Blanket exclusion per NCD 164 Final Notice, November 20, 1992

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CMS Thermography Billing Guidelines and Action Items 2026

Given the scope of this exclusion, your action items are operational — not clinical. The goal is to stop these claims before they're submitted, not recover them after denial.

Copy Action Items

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CPT, HCPCS, and ICD-10 Codes for Thermography Under NCD 164

No Codes Listed in Policy Data

NCD 164 does not list any CPT, HCPCS, or ICD-10 codes. This is consistent with the blanket exclusion — there is no billing code pathway for thermography under Medicare, covered or otherwise.

This absence matters for your billing team. It means there is no code to attach medical necessity criteria to. There is no code to submit with a specific diagnosis and expect review. The exclusion operates at the service level, not the code level.

If your billing software or charge master has ever had a thermography code configured for Medicare billing, that configuration is wrong and should be corrected.

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Why This Policy Still Matters in 2026

Some billing teams will look at this update and think: "We don't bill thermography. This doesn't apply to us." That may be true. But there are three reasons to pay attention anyway.

First, thermography marketing has surged in recent years — particularly for breast cancer screening. Practices in markets with active thermography promotion may see patient requests more often than expected. Knowing the exclusion is absolute lets your staff answer confidently.

Second, the fact that CMS issued a modification to NCD 164 in 2026 suggests the agency is actively reviewing this policy. Modifications to long-standing NCDs sometimes precede broader updates. This is worth tracking.

Third, understanding categorical exclusions — how they differ from experimental designations, what they mean for ABN requirements, and how they interact with commercial payer policies — is foundational billing knowledge. Not every payer follows CMS. Some commercial plans may cover thermography under specific protocols. Your billing team needs to know not to assume CMS's exclusion applies across all payers automatically.

If you see thermography showing up in your denial queue from Medicare, that's a sign your charge capture or payer routing needs a fix. Run that audit before March 7, 2026.

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