CMS Confirms MECT Is Not Covered Under Medicare: What Billing Teams Need to Know

The Centers for Medicare & Medicaid Services has issued a modification to National Coverage Determination (NCD) 278, reaffirming that Multiple Electroconvulsive Therapy (MECT) is not covered under the Medicare program. This update makes explicit what the policy has long held: CMS does not consider MECT reasonable and necessary due to unverified clinical effectiveness and demonstrated risks. Billing teams submitting claims for MECT procedures to Medicare should expect denial, and providers counseling patients on this treatment need to understand the coverage limitations before services are rendered.

What Is MECT and Why Does CMS NCD 278 Matter?

Standard electroconvulsive therapy (ECT) involves inducing a single therapeutic seizure per treatment session and has a well-established Medicare coverage record for specific psychiatric conditions. MECT—Multiple Electroconvulsive Therapy—differs in that it involves inducing multiple seizures within a single session, a variation intended to potentially intensify or accelerate therapeutic effect.

NCD 278 addresses this distinction directly. CMS has evaluated MECT separately from standard ECT and reached a clear, non-coverage determination. This matters to billing teams because MECT and standard ECT are distinct clinical protocols, and conflating the two in documentation or coding could introduce audit exposure or compliance risk.

The policy modification effective March 12, 2026, reinforces CMS's longstanding position and should prompt practices to audit any documentation or order sets that reference MECT as a treatment option for Medicare beneficiaries.

CMS Medical Necessity Standard for MECT: Why It Fails Coverage

CMS applies the "reasonable and necessary" standard under Section 1862(a)(1)(A) of the Social Security Act when determining Medicare coverage. For MECT, CMS has concluded the service does not meet that threshold—on two grounds.

First, clinical effectiveness has not been verified. CMS states explicitly that the clinical effectiveness of multiple-seizure electroconvulsive therapy "has not been verified by scientifically controlled studies." Without that evidentiary foundation, CMS cannot establish that the service provides meaningful clinical benefit to Medicare beneficiaries.

Second, the risk profile is unfavorable. Beyond the absence of efficacy data, CMS notes that "studies have demonstrated an increased risk of adverse effects with multiple seizures." This means MECT isn't simply unproven—it carries documented safety concerns that further disqualify it from meeting the reasonable and necessary standard.

Together, these findings place MECT firmly outside Medicare coverage. No amount of clinical documentation from individual providers will override a National Coverage Determination. Practices should not submit MECT claims expecting case-by-case medical necessity reviews to result in payment.

Coverage vs. Non-Coverage: MECT Versus Standard ECT Under Medicare

This is a distinction your clinical and coding teams need to understand precisely.

Standard ECT—single-seizure electroconvulsive therapy—has separate Medicare coverage guidance and is not the subject of NCD 278. Providers performing standard ECT for covered indications should not interpret this policy update as affecting those claims. NCD 278 applies specifically and exclusively to the multiple-seizure variant.

MECT, as defined in NCD 278, is categorically non-covered under Medicare. This is a national, blanket determination—not a local coverage decision that varies by MAC jurisdiction. Every Medicare Administrative Contractor is bound by this NCD.

If a provider believes a Medicare beneficiary could benefit from MECT and the patient wants to pursue it, the appropriate process is to issue an Advance Beneficiary Notice of Noncoverage (ABN) before the service is rendered. This allows the patient to make an informed financial decision and permits the provider to bill the patient directly.

Affected Codes

The policy does not list specific CPT, HCPCS, or ICD-10 codes. NCD 278 addresses MECT as a procedure category without assigning discrete billing codes to the non-covered service. This is consistent with how CMS handles some non-coverage determinations—particularly for procedures that lack a distinct, widely used code because they are not routinely billed.

Implications for your billing team: The absence of a specific code does not reduce your compliance obligation. If a claim is submitted for a service that functions as MECT—regardless of how it is coded—and it is identified as such through clinical documentation review, the non-coverage determination applies. Work with your clinical staff and compliance team to ensure MECT is not being billed under adjacent ECT codes.

There are no covered codes, experimental codes, or diagnosis code tables to present from this policy, as the source document does not enumerate specific codes. For the most current CMS transmittal guidance, reference Transmittal AB-03-003, which CMS cross-references in NCD 278.

What Your Billing Team Should Do