CMS Pulmonary Rehabilitation Coverage Policy: What NCD 320 Means for Your Billing Team in 2026

The Centers for Medicare & Medicaid Services (CMS) updated NCD 320, its National Coverage Determination for Pulmonary Rehabilitation Services, with a review date of March 12, 2026. The core position of this policy has not shifted—CMS continues to defer coverage determinations to local Medicare Administrative Contractors (MACs) rather than establishing a uniform national standard. For billing teams, that means your coverage landscape for pulmonary rehab is still defined at the regional level, and knowing your MAC's LCD is non-negotiable.

What CMS NCD 320 Actually Says About Pulmonary Rehabilitation Coverage

The short version: CMS has formally declined to set a national coverage determination for comprehensive pulmonary rehabilitation programs as a distinct Part B benefit. That position, unchanged since at least the 2007 review, is reaffirmed here.

CMS references the widely accepted 1999 joint definition from the American Thoracic Society (ATS) and the European Respiratory Society (ERS) describing pulmonary rehabilitation as a multi-disciplinary, individually tailored program for patients with chronic respiratory impairment. The program's goals—reducing symptoms, optimizing functional status, increasing patient participation, and reducing downstream healthcare costs—are well-established in the clinical literature.

Despite that clinical foundation, CMS has determined that the Social Security Act does not expressly define a comprehensive Pulmonary Rehabilitation Program as a Part B benefit. This is a critical billing distinction. Individual services that make up a pulmonary rehab program may be covered under separate Medicare benefit categories, but the bundled, comprehensive program itself does not have a nationally defined benefit category under NCD 320.

The MAC LCD Framework: Why Your Geographic Location Determines Coverage

Because CMS has not issued national coverage criteria, local Medicare Administrative Contractors retain full authority to determine coverage through the Local Coverage Determination (LCD) process—or by adjudicating claims on a case-by-case basis under §1862(a)(1)(A) of the Social Security Act.

This means two providers offering the same pulmonary rehab services could face completely different coverage requirements depending on which MAC administers their region. What constitutes "medically necessary" pulmonary rehabilitation for a patient with COPD in one jurisdiction may require different documentation in another.

CMS directs providers to search active LCDs through the Medicare Coverage Database at cms.gov. If your billing team hasn't pulled your MAC's current LCD for pulmonary rehabilitation recently, that is your first action item.

Respiratory Therapy Under the CORF Benefit: A Separate Coverage Pathway

NCD 320 notes one specific carve-out worth flagging for billing teams: respiratory therapy services are covered under the Comprehensive Outpatient Rehabilitation Facility (CORF) benefit. This is codified at 42 CFR 410.100(e)(1) through (e)(2)(vi).

For practices or facilities billing under the CORF benefit, respiratory therapy—including components that may overlap with pulmonary rehabilitation—has a defined coverage pathway that exists independently of the NCD 320 framework. If your facility is CORF-certified, this regulatory hook is important for how you structure and bill these services.

Practices that are not CORF-certified should not assume this pathway applies to them. The CORF benefit comes with its own certification requirements, service conditions, and billing rules.

Prior Authorization and Medical Necessity Under NCD 320

NCD 320 does not establish nationally covered or nationally non-covered indications. There are no CMS-defined medical necessity criteria at the national level for pulmonary rehabilitation as a comprehensive program. Prior authorization requirements, if applicable, will be set by your MAC or by supplemental payer contracts—not by this NCD.

For Medicare Advantage plans, note that individual plan policies may impose additional coverage criteria beyond what fee-for-service Medicare requires. Always verify plan-specific requirements separately from the NCD.

Affected Codes

This policy does not list specific CPT, HCPCS, or ICD-10 codes. NCD 320 does not define covered or non-covered codes at the national level—code-level coverage guidance lives within individual MAC LCDs. Contact your MAC or search the Medicare Coverage Database to identify the specific codes addressed in your region's LCD.

What Your Billing Team Should Do