CMS Percutaneous Image-Guided Breast Biopsy Coverage Policy Updated for 2026 (NCD 272)
CMS has issued a modification to National Coverage Determination 272, governing Medicare coverage for percutaneous image-guided breast biopsy. This update affects how facilities and physician practices document medical necessity and submit claims for both non-palpable and palpable breast lesion biopsies performed under ultrasound or stereotactic guidance. Billing teams across radiology, surgery, and women's health need to review their documentation workflows now—before the March 12, 2026 effective date.
| Field | Detail |
|---|---|
| Payer | Centers for Medicare & Medicaid Services (CMS) |
| Policy | Percutaneous Image-Guided Breast Biopsy |
| Policy Code | NCD 272 |
| Change Type | Modified |
| Effective Date | 2026-03-12 |
| Impact Level | Medium |
| Specialties Affected | Radiology, Breast Surgery, General Surgery, Ambulatory Surgical Centers, Outpatient Hospital Facilities |
| Key Action | Audit documentation protocols to confirm BIRADS grading is recorded and medical necessity criteria for palpable vs. non-palpable lesions are clearly supported in the medical record. |
What NCD 272 Covers: CMS Medicare Criteria for Image-Guided Breast Biopsy
Percutaneous image-guided breast biopsy is a minimally invasive procedure in which a tissue sample is obtained through a small skin incision using real-time imaging guidance—either ultrasound or stereotactic (mammography-based) systems. It is used as an alternative to open surgical biopsy when a radiographic abnormality is identified and tissue sampling is required for diagnosis.
The Centers for Medicare & Medicaid Services established coverage for this procedure effective January 1, 2003 under NCD 272, and the 2026 modification carries forward the core coverage framework. The policy applies across four benefit categories: Ambulatory Surgical Center Facility Services, Inpatient Hospital Services, Outpatient Hospital Services Incident to a Physician's Service, and Physicians' Services.
The foundation of medical necessity documentation under this NCD is the Breast Imaging Reporting and Data System (BIRADS), developed by the American College of Radiology. BIRADS provides a standardized grading system that radiologists use when interpreting mammograms, and CMS has anchored coverage eligibility directly to these grades.
CMS BIRADS Grade Requirements for Medicare Coverage
Understanding the BIRADS scale is non-negotiable for any billing team submitting claims under NCD 272. Here's the full grading structure as referenced in the policy:
| BIRADS Grade | Interpretation |
|---|---|
| Grade I | Negative |
| Grade II | Benign finding |
| Grade III | Probably benign |
| Grade IV | Suspicious abnormality |
| Grade V | Highly suggestive of malignant neoplasm |
Medicare coverage under NCD 272 is only available when the radiographic abnormality is graded BIRADS III, IV, or V. Lesions graded BIRADS I or II do not meet coverage criteria, and claims submitted without documented BIRADS grading at the qualifying level will be vulnerable to denial.
Non-Palpable vs. Palpable Breast Lesions: How CMS Distinguishes Coverage
NCD 272 draws a clear line between two clinical scenarios, and your documentation must address which situation applies.
Non-Palpable Breast Lesions
Medicare covers percutaneous image-guided breast biopsy—using either stereotactic or ultrasound imaging—for radiographic abnormalities that are non-palpable and graded BIRADS III, IV, or V. The non-palpable designation means the lesion cannot be felt on physical examination and was identified through imaging. This is the more straightforward coverage pathway, provided the BIRADS grade is documented.
Palpable Breast Lesions
Coverage also extends to palpable lesions—those that can be detected on physical exam—but only when the lesion is determined to be difficult to biopsy using palpation alone. This is a more nuanced determination, and CMS explicitly delegates discretion here to Medicare Administrative Contractors (MACs). Your regional MAC has the authority to define what types of palpable lesions qualify as difficult to biopsy by palpation.
This MAC-level discretion is a significant compliance point. A palpable lesion biopsy that clears coverage in one MAC jurisdiction may not clear it in another. Billing teams operating across multiple regions—or facilities that recently changed MAC jurisdiction—must verify their specific contractor's published guidance on this criterion.
Prior Authorization and Experimental Designations Under NCD 272
The policy does not specify a prior authorization requirement within the NCD itself. However, given that MACs retain discretion over palpable lesion determinations, it is advisable to check your contractor's Local Coverage Determinations (LCDs) for any additional prior authorization or pre-certification steps they may impose at the local level.
There are no experimental or investigational designations within NCD 272. Both stereotactic and ultrasound guidance modalities are recognized as covered approaches under the same coverage criteria.
| 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 |
Affected Codes
The policy document for NCD 272 does not list specific CPT or HCPCS codes within its text. CMS has not enumerated procedure codes directly in this NCD. Billing teams should reference their MAC's corresponding LCD and associated Billing and Coding Article for the specific CPT codes applicable to percutaneous image-guided breast biopsy procedures in their jurisdiction. There are no ICD-10-CM diagnosis codes listed in this policy document.
No covered or non-covered code tables can be constructed from this policy data—fabricating codes here would create compliance risk. Contact your MAC or consult a current coding reference to identify the applicable procedure codes.
What Your Billing Team Should Do
| # | Action Item |
|---|---|
| 1 | Pull your MAC's current LCD and Billing and Coding Article before March 12, 2026. Since NCD 272 delegates palpable lesion determinations to MAC discretion, your local contractor's guidance is not optional reading—it defines what qualifies for coverage in your region. Identify your MAC at cms.gov and confirm whether they have published updated guidance in connection with this NCD modification. |
| 2 | Update documentation templates to require BIRADS grade on every breast biopsy order and in the clinical note. Claims for BIRADS I or BIRADS II lesions will not meet coverage criteria. Your intake and pre-authorization checklists should flag these cases before the procedure is scheduled—not after it's billed. |
| 3 | For palpable lesion cases, require the ordering physician to document why palpation-guided biopsy is insufficient. This documentation is the hinge point for MAC review. A vague note isn't enough—the record should explain the specific anatomical, clinical, or technical factors that make image guidance medically necessary for a palpable lesion. |
| 4 | Audit claims submitted after March 12, 2026 for a 60-day post-implementation period. Review a sample of paid and denied claims against the updated NCD criteria to catch any documentation gaps early. Denials tied to BIRADS grade or palpability status are recoverable with the right medical record support, but appeals are easier to win when documentation was built correctly from the start. |
| 5 | Brief your radiology and surgical coding staff on the non-palpable vs. palpable distinction. These two coverage pathways require different supporting documentation, and coders need to know which scenario they're working with before claim submission. |
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