Hemorheograph — NCD 180 | CMS Coverage Update

TL;DR: The Centers for Medicare & Medicaid Services modified NCD 180 for hemorheograph services, effective March 7, 2026. Coverage is limited to preoperative and postoperative diagnostic evaluation of suspected peripheral artery disease — and this policy lists no specific CPT or HCPCS codes, which creates real documentation and coding risk for your billing team.

Quick-Reference Table

CMS Hemorheograph Coverage Criteria and Medical Necessity Requirements 2026

NCD 180 is the National Coverage Determination governing Medicare coverage of hemorheograph diagnostic services. The Centers for Medicare & Medicaid Services classifies this under the Diagnostic Tests (other) benefit category.

The CMS hemorheograph coverage policy has a narrow scope. Medicare pays for hemorheograph services only when the procedure is performed for preoperative or postoperative diagnostic evaluation of suspected peripheral artery disease. That's the full extent of covered use.

The policy does acknowledge the hemorheograph's clinical role. It's described as safe and effective for determining the adequacy of skin perfusion before minor surgical procedures on the extremities — including minor podiatric procedures — and as an adjunct to evaluating patients suspected of having peripheral vascular disease. But "safe and effective" doesn't mean "always covered." Medical necessity under this coverage policy is tied specifically to the perioperative evaluation context.

If your practice uses a hemorheograph for general screening or routine vascular assessment outside a surgical context, those claims don't meet medical necessity under this NCD. That's a clean denial risk. Document the clinical indication clearly — preoperative or postoperative, suspected peripheral artery disease — before you submit.

Prior authorization isn't mentioned in this NCD as a specific requirement. That said, your Medicare Administrative Contractor may apply additional local coverage determination requirements on top of this NCD. Check with your MAC before assuming this NCD alone governs all coverage decisions in your region.

CMS Hemorheograph Exclusions and Non-Covered Indications

This NCD contains a critical technical distinction that your billing team needs to understand before coding.

The hemorheograph is not a plethysmograph. CMS makes this explicit. A plethysmograph measures and records changes in the size of a body part as modified by blood circulation. The hemorheograph measures surface blood flow in the skin. It does not measure total blood flow in a digit or limb.

Why does this matter for hemorheograph billing? Because plethysmography has its own set of CPT codes and coverage rules. If a provider or coder conflates the two instruments and uses plethysmography codes to bill hemorheograph services, that's a miscoded claim. It's also the kind of error that shows up in MAC audits.

The real issue here is that coders who aren't familiar with both instruments may reach for familiar plethysmography codes by default. The policy exists partly to prevent that. Train your coding staff on the distinction. It's a short conversation that prevents a painful reimbursement clawback.

Any use of the hemorheograph that falls outside preoperative or postoperative evaluation of suspected peripheral artery disease is not covered under this NCD. That includes using it solely as a standalone diagnostic tool for general peripheral vascular disease screening without a surgical procedure in the picture.

Coverage Indications at a Glance

CMS Hemorheograph Billing Guidelines and Action Items 2026

This is where the policy's ambiguity becomes a practical problem. NCD 180 sets clear coverage criteria but lists no CPT or HCPCS codes. That puts the coding burden entirely on your team. Here's how to handle it.

CPT, HCPCS, and ICD-10 Codes for Hemorheograph Services Under NCD 180

Covered CPT/HCPCS Codes

NCD 180 does not list specific CPT or HCPCS codes. This is a significant gap in the policy. Your billing team cannot rely on this NCD alone for code selection.

Contact your Medicare Administrative Contractor to confirm which procedure codes are appropriate for hemorheograph services in your region. Document that conversation and keep it on file. If your MAC provides written guidance, treat it as binding for your claims submission process.

Key ICD-10-CM Diagnosis Codes

NCD 180 does not list specific ICD-10-CM diagnosis codes. Based on the policy criteria — suspected peripheral artery disease, preoperative or postoperative context — your diagnosis coding should reflect that clinical picture. Work with your clinical documentation improvement team and your MAC to identify appropriate diagnosis codes for your claims.

The absence of specific codes in this NCD is the single biggest operational risk it creates for your billing team. Don't treat this as a minor administrative detail. A claim submitted with the wrong procedure code — even with perfect documentation — will deny. Get MAC guidance in writing before the effective date.