CMS Acupuncture for Osteoarthritis Coverage Policy (NCD 284): What Billing Teams Need to Know in 2026

The Centers for Medicare & Medicaid Services (CMS) has issued a modified update to National Coverage Determination (NCD) 284, which governs Medicare coverage of acupuncture for osteoarthritis. This policy change, effective March 12, 2026, reaffirms and maintains the longstanding national non-coverage determination that has been in place since April 16, 2004. Billing teams submitting claims for acupuncture services directed at osteoarthritis patients should treat this as a firm coverage denial baseline—there is no pathway to Medicare reimbursement for this indication.

What CMS NCD 284 Actually Says About Acupuncture and Osteoarthritis Coverage

CMS defines acupuncture broadly as "the selection and manipulation of specific acupuncture points by a variety of needling and non-needling techniques." That definition is intentionally wide—it captures dry needling variants, electroacupuncture, and pressure-point techniques, not just traditional needle insertion.

Despite that broad procedural scope, NCD 284 contains no nationally covered indications for acupuncture when osteoarthritis is the diagnosis driving the claim. The "Nationally Covered Indications" section is explicitly listed as not applicable (N/A) for this condition.

What the policy does contain—clearly and without exception—is a national non-coverage determination. CMS concluded after its April 2004 review that "there is no convincing evidence for the use of acupuncture for pain relief in patients with osteoarthritis." CMS further noted that study design flaws at the time "prohibit assessing acupuncture's utility for improving health outcomes." That evidentiary bar has not been cleared in the decades since, and this 2026 modification confirms the determination stands.

The Medical Necessity Standard CMS Applies Here

The statutory basis for this denial matters for billing teams building denial management workflows. CMS cites §1862(a)(1) of the Social Security Act as the governing authority—the provision requiring that services be "reasonable and necessary" for diagnosis or treatment of illness or injury.

CMS has explicitly determined that acupuncture for osteoarthritis does not meet that reasonable and necessary standard. This is not a coverage exclusion based on benefit category limits or a lack of an applicable HCPCS code—it is a medical necessity denial embedded in a binding NCD.

That distinction is important: NCDs take precedence over Local Coverage Determinations (LCDs) and cannot be overridden at the MAC level. A Medicare Administrative Contractor cannot grant coverage that a national determination prohibits, and providers cannot successfully appeal a claim denied under this NCD by arguing medical necessity at the local level.

CMS Benefit Categories Under Which This Policy Applies

NCD 284 explicitly identifies the benefit categories under which this coverage determination applies:

• Incident to a physician's professional service — Acupuncture delivered as part of a broader physician encounter falls under this determination when osteoarthritis is the driving diagnosis.
• Inpatient hospital services — The non-coverage determination applies in the inpatient setting as well, meaning facility billing teams are equally bound.
• Physicians' services — Acupuncture billed by or under the supervision of a physician for osteoarthritis is non-covered.

CMS notes this may not be an exhaustive list of applicable benefit categories. Billing teams should not assume coverage is available under a benefit category not listed here—the non-coverage determination is condition-specific (osteoarthritis), not setting-specific.

Important Contrast: CMS Does Cover Acupuncture for Chronic Low Back Pain

This is where billing teams often get tripped up. CMS does cover acupuncture—but only for chronic low back pain (cLBP), under a separate NCD that went into effect in 2020 following a coverage with evidence development (CED) pathway. That coverage is limited to up to 12 visits in 90 days, with an additional eight sessions for patients demonstrating improvement.

Osteoarthritis and chronic low back pain are distinct indications with distinct coverage determinations. A patient presenting with knee osteoarthritis and comorbid low back pain cannot have acupuncture services cross-applied between diagnoses to secure reimbursement. The primary diagnosis on the claim drives the coverage determination, and osteoarthritis as a primary diagnosis triggers the non-covered status under NCD 284.

Make sure your clinical documentation and coding workflows clearly separate these two patient populations.

Affected Codes

NCD 284 as published does not list specific CPT or HCPCS codes in its applicable codes section. No code-level coverage or non-coverage assignments are enumerated in this policy document.

Billing implication: The absence of specific codes in the NCD does not create a coverage loophole. The non-coverage determination is condition-based and applies regardless of which procedure code is used to bill acupuncture services when osteoarthritis is the primary diagnosis. Submitting acupuncture claims under any procedure code with an osteoarthritis ICD-10-CM diagnosis (such as M15–M19 series codes) to Medicare will result in denial under this NCD.

For claims processing guidance, CMS directs billers to Transmittal 10128 of the Medicare Claims Processing Manual, available at https://www.cms.gov/files/document/r10128CP.pdf.

What Your Billing Team Should Do