CMS Infrared Therapy Devices Policy (NCD 315): What Billing Teams Need to Know in 2026

CMS has issued a modification to National Coverage Determination NCD 315, which governs Medicare coverage of infrared therapy devices classified under Durable Medical Equipment. This policy has been non-coverage since October 2006, and the 2026 update maintains that position—but the administrative refresh signals that billing teams should reconfirm their internal workflows and denial management processes are aligned with the current policy language.

Field Detail
Payer CMS (Centers for Medicare & Medicaid Services)
Policy Infrared Therapy Devices
Policy Code NCD 315
Change Type Modified
Effective Date 2026-03-12
Impact Level Medium
Specialties Affected Podiatry, Wound Care, Neurology, Physical Medicine & Rehabilitation, DME Suppliers
Key Action Confirm your billing workflows flag infrared therapy device claims for automatic denial under NCD 315 before submitting to Medicare.

CMS Infrared Therapy Device Coverage Policy: What NCD 315 Actually Says

The Centers for Medicare & Medicaid Services has maintained a firm non-coverage determination for infrared therapy devices since October 24, 2006. Under NCD 315, CMS has concluded there is sufficient evidence that the use of infrared therapy devices and any related accessories is not reasonable and necessary under section 1862(a)(1)(A) of the Social Security Act.

That statutory reference matters. Section 1862(a)(1)(A) is Medicare's foundational "reasonable and necessary" exclusion. When CMS invokes it in an NCD, the determination is national, binding, and not subject to local contractor discretion. There's no path to coverage through a Local Coverage Determination (LCD) override on these specific indications.

The 2026 modification to this policy is an administrative update to NCD 315. The core non-coverage language remains intact, but billing teams should treat any CMS policy modification as a trigger for internal policy review—even when the underlying coverage position hasn't changed.


What Infrared Therapy Devices Are—and Why They're Billed

Infrared therapy devices deliver infrared therapy energy to the skin and adjacent subcutaneous tissues. The device typically consists of an array of juxtaposed infrared diodes affixed to a flexible pad designed to maintain skin contact. Some devices also produce local warming, though CMS treats that as a secondary effect, not the primary therapeutic mechanism.

These devices have been marketed and billed for a range of conditions, including:

This is exactly where billing errors tend to cluster. A patient with diabetic foot complications presents for wound care or neuropathy treatment. A provider uses an infrared therapy device as part of the treatment protocol. The claim goes to Medicare. NCD 315 makes that claim non-covered—period.

Importantly, the non-coverage extends to monochromatic infrared energy (MIRE) devices and near-infrared light therapy, not just traditional infrared heat lamps. If the device uses infrared or near-infrared light and/or heat for any of the listed indications, NCD 315 applies.


Non-Coverage Is Total: No Exceptions Under NCD 315

This is worth stating directly because it affects how your team handles patient conversations, ABN (Advance Beneficiary Notice) processes, and denial management.

There are no nationally covered indications under NCD 315. CMS has not identified any condition, patient population, or clinical scenario under which infrared therapy devices are covered for Medicare beneficiaries. The policy lists zero exceptions.

The non-coverage applies to:

That last point—coverage denial extending to symptom treatment—means a provider can't bill an infrared device claim under a pain management code to sidestep the neuropathy or wound exclusion. The condition driving the pain matters, and if that condition is on the non-covered list, the claim is denied regardless of how it's coded.


Sample Version Diff Line-by-line changes
Previous VersionCurrent Version
Coverage is considered experimental and investigational for all indicationsCoverage is considered medically necessary when specific criteria are met
Prior authorization is not requiredPrior authorization is required for initial treatment
Documentation must include clinical historyDocumentation must include clinical history
Re-review every 24 monthsRe-review every 12 months with updated clinical documentation

Affected Codes

The policy data does not list specific CPT or HCPCS codes for NCD 315. This is not unusual for older DME-category NCDs. For billing purposes, your DME coding team should reference the applicable HCPCS codes for infrared therapy devices through the CMS claims processing transmittals associated with this policy: Transmittal 1127 and Transmittal 1183 (Medicare Claims Processing). These transmittals contain the specific claims processing instructions CMS issued when the original non-coverage determination became effective.

No ICD-10 diagnosis codes are listed in the current policy document.

Practical note for billers: Because no specific codes are enumerated in NCD 315 itself, apply this policy by indication—not by code. If the clinical documentation supports a diagnosis of peripheral neuropathy (diabetic or otherwise), wounds, or ulcers of the skin or subcutaneous tissues, and the device used is infrared-based, the claim is non-covered under this NCD regardless of which HCPCS E-code or A-code is used to report the equipment.


ABN Requirements and Patient Financial Responsibility

When a service is non-covered under a national coverage determination, providers who choose to furnish the service anyway must issue a valid Advance Beneficiary Notice of Noncoverage (ABN) before delivery. Without a properly executed ABN, the provider cannot bill the patient for the service if Medicare denies it.

For infrared therapy devices specifically:

Failing to issue an ABN means absorbing the cost entirely if Medicare denies the claim. Given that NCD 315 represents a predictable, known denial, there's no excuse for a missing ABN on these services.


This policy is now in effect (since 2026-03-12). Verify your claims match the updated criteria above.

What Your Billing Team Should Do

#Action Item
1

Audit your DME billing workflows by March 12, 2026. Confirm that your practice management or billing system has a hard stop—or at minimum a warning flag—when an infrared therapy device is scheduled or ordered for a Medicare patient with a diagnosis of peripheral neuropathy, skin ulcers, or wounds. This should already be in place, but the policy modification is the right trigger for a spot check.

2

Pull 90 days of denied claims and look for pattern denials under NCD 315. If your team has been submitting these claims and receiving denials, calculate the write-off exposure. If the ABN process wasn't followed, determine whether any corrective action or patient notification is warranted.

3

Update your ABN issuance protocols for any provider using infrared therapy devices. Document the process: who generates the ABN, when it's presented to the patient, and where the signed form is stored in the patient record. This protects the practice's ability to collect from patients when Medicare predictably denies.

+ 2 more action items

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