TL;DR: The Centers for Medicare & Medicaid Services modified NCD 180, the National Coverage Determination governing Medicare hemorheograph coverage, effective March 7, 2026. Here's what changes for billing teams.
CMS hemorheograph coverage policy under NCD 180 has been updated. The policy confirms that Medicare covers hemorheograph services only for preoperative and postoperative diagnostic evaluation of suspected peripheral artery disease. This policy does not list specific CPT or HCPCS codes — a detail your billing team needs to address before submitting claims.
Quick-Reference Table
| Field | Detail |
|---|---|
| Payer | CMS (Centers for Medicare & Medicaid Services) |
| Policy | Hemorheograph |
| Policy Code | NCD 180 |
| Change Type | Modified |
| Effective Date | 2026-03-07 |
| Impact Level | Medium |
| Specialties Affected | Podiatry, Vascular Surgery, Peripheral Vascular Medicine, General Surgery |
| Key Action | Confirm your billing team uses the correct codes for hemorheograph services and that documentation reflects preoperative or postoperative peripheral artery disease evaluation — not general skin perfusion screening |
CMS Hemorheograph Coverage Criteria and Medical Necessity Requirements 2026
NCD 180 is the National Coverage Determination governing Medicare coverage of hemorheograph services. The policy is narrow. Medicare reimbursement is available only when the hemorheograph is used for preoperative and postoperative diagnostic evaluation of patients suspected of having peripheral artery disease.
That's the entire covered indication. CMS does not cover hemorheograph billing for general skin perfusion assessment, routine podiatric screening, or any use unconnected to peripheral artery disease evaluation.
The medical necessity standard here is direct: the patient must be suspected of having peripheral artery disease, and the hemorheograph must be used as part of pre- or postoperative workup. If your documentation doesn't reflect that clinical context, you're looking at a claim denial. Your physicians' notes need to connect the dots explicitly.
The policy also acknowledges a legitimate secondary use — assessing skin perfusion before minor surgical procedures on the extremities, including minor podiatric procedures. But note that this use is only covered when it falls within the preoperative evaluation framework for suspected peripheral artery disease. A standalone skin perfusion check before nail surgery, without a documented peripheral artery disease evaluation, does not meet the coverage policy's medical necessity threshold.
Prior authorization is not explicitly mentioned in NCD 180 for hemorheograph services. That said, your Medicare Administrative Contractor may have additional local coverage determination requirements that sit on top of this national policy. Check with your MAC before assuming prior auth is off the table for your region.
CMS Hemorheograph Exclusions and Non-Covered Indications
The real issue here is scope creep in documentation. Hemorheograph billing gets into trouble when practices use the device for purposes that sound clinical but fall outside the NCD 180 coverage policy.
CMS is explicit: the hemorheograph is not a plethysmograph. This distinction matters for billing. A plethysmograph measures total blood flow changes in a digit or limb by recording changes in body part size. The hemorheograph measures surface blood flow in the skin only. These are different instruments with different coverage rules.
If your practice has been treating the hemorheograph as interchangeable with plethysmography — or billing it as if it were — that's a compliance problem. CMS defines them separately, and mixing up the two creates incorrect billing, which means claim denials and potential audit exposure.
Services not covered under NCD 180 include:
| # | Excluded Procedure |
|---|---|
| 1 | Hemorheograph use outside preoperative or postoperative evaluation contexts |
| 2 | Use as a general screening tool without documented suspicion of peripheral artery disease |
| 3 | Any application where the clinical record doesn't support the peripheral artery disease evaluation pathway |
If you're not certain whether a specific clinical scenario fits the coverage policy, loop in your compliance officer before the effective date of March 7, 2026.
Coverage Indications at a Glance
| Indication | Status | Relevant Codes | Notes |
|---|---|---|---|
| Preoperative evaluation of suspected peripheral artery disease | Covered | Not specified in NCD 180 — confirm with MAC | Documentation must reflect PAD suspicion |
| Postoperative evaluation of suspected peripheral artery disease | Covered | Not specified in NCD 180 — confirm with MAC | Same documentation standard applies |
| Skin perfusion assessment before minor extremity surgery (including podiatric procedures) | Covered only as part of PAD evaluation | Not specified in NCD 180 | Standalone skin perfusion check without PAD workup is not covered |
| General screening without suspected peripheral artery disease | Not Covered | N/A | No medical necessity basis under NCD 180 |
| Use as a plethysmograph substitute | Not Covered | N/A | CMS explicitly distinguishes these instruments |
CMS Hemorheograph Billing Guidelines and Action Items 2026
The absence of specific CPT or HCPCS codes in NCD 180 creates real risk. Here's what your billing team needs to do before and after March 7, 2026.
| # | Action Item |
|---|---|
| 1 | Contact your MAC immediately. NCD 180 does not list specific CPT or HCPCS codes for hemorheograph services. Your Medicare Administrative Contractor controls the local coverage determination and the code set you should use. Call them or check their LCD database before submitting claims. |
| 2 | Audit your documentation templates now. Pull your current intake and procedure notes for hemorheograph services. Every note must document that the patient is suspected of having peripheral artery disease and that the service is part of pre- or postoperative evaluation. Vague references to "vascular screening" or "skin perfusion" alone will not meet the medical necessity standard. |
| 3 | Train your physicians on the PAD documentation requirement. The coverage policy ties reimbursement directly to documented suspicion of peripheral artery disease. If the physician's note doesn't say it, the claim doesn't have it. Run a brief training before the effective date of March 7, 2026. |
| 4 | Separate hemorheograph and plethysmograph billing pathways. These instruments have different coverage rules under Medicare billing guidelines. If your practice uses both, make sure your charge capture system treats them as distinct services with distinct documentation and code sets. Conflating them is the fastest route to a claim denial under this policy. |
| 5 | Review any pending or recently submitted claims. If you've submitted hemorheograph claims without documented peripheral artery disease evaluation context, assess your exposure now. Correct and refile where possible before audit risk compounds. |
| 6 | Flag this for your compliance officer. The narrow scope of NCD 180 — combined with the absence of specific codes — makes this a documentation compliance issue as much as a billing one. Your compliance officer should review your current workflows against the updated coverage policy. |
| 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 Hemorheograph Under NCD 180
Covered Codes
NCD 180 does not list specific CPT or HCPCS codes for hemorheograph services.
This is not a gap in this summary — it's the actual state of the policy. The coverage policy establishes the clinical criteria and coverage framework, but it does not assign a specific code set. Your Medicare Administrative Contractor will determine which codes apply in your region through their local coverage determination process.
| Code | Type | Description |
|---|---|---|
| Not specified | — | Contact your MAC for applicable codes in your jurisdiction |
Key ICD-10-CM Diagnosis Codes
NCD 180 does not list specific ICD-10-CM codes. However, given the coverage policy's restriction to suspected peripheral artery disease, your documentation should support a peripheral artery disease diagnosis code. Confirm the appropriate ICD-10-CM codes with your MAC or billing consultant, as the clinical specificity of the diagnosis code will affect whether your claim holds up under medical necessity review.
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