CMS Noncoverage Policy for Thermal Intradiscal Procedures (TIPs) Stands Firm: What Billing Teams Must Know in 2026
The Centers for Medicare & Medicaid Services (CMS) has issued a modified update to NCD 324, its National Coverage Determination governing thermal intradiscal procedures (TIPs). This policy—originally finalized in September 2008—maintains a blanket noncoverage determination for all TIPs used in the treatment of low back pain, effective for services performed on or after March 12, 2026. If your practice or facility performs procedures like intradiscal electrothermal therapy (IDET), intradiscal biacuplasty (IDB), or percutaneous disc decompression (PDD), this update has direct implications for how your billing team should be handling claims.
| Field | Detail |
|---|---|
| Payer | CMS (Centers for Medicare & Medicaid Services) |
| Policy | Thermal Intradiscal Procedures (TIPs) |
| Policy Code | NCD 324 |
| Change Type | Modified |
| Effective Date | 2026-03-12 |
| Impact Level | High |
| Specialties Affected | Pain Management, Orthopedic Surgery, Neurosurgery, Interventional Radiology, Physical Medicine & Rehabilitation |
| Key Action | Cease billing Medicare for any TIP procedure used to treat low back pain and ensure denial management workflows are updated to reflect the noncoverage determination. |
What Is Covered Under CMS NCD 324 — and What Isn't
Let's be direct: there are no nationally covered indications under NCD 324. CMS has determined that TIPs are not reasonable and necessary for the treatment of low back pain under the Medicare program. That determination has not changed with this 2026 modification.
The policy's noncoverage applies broadly to all percutaneous thermal intradiscal procedures that use a radiofrequency energy source or electrothermal energy. The procedures covered under this NCD's scope include, but are not limited to:
- Intradiscal electrothermal therapy (IDET)
- Intradiscal thermal annuloplasty (IDTA)
- Percutaneous intradiscal radiofrequency thermocoagulation (PIRFT)
- Radiofrequency annuloplasty (RA)
- Intradiscal biacuplasty (IDB)
- Percutaneous (or plasma) disc decompression (PDD) / coblation
- Targeted disc decompression (TDD)
The noncoverage determination also applies to procedures identified by the name of the catheter or probe used—including SpineCath, discTRODE, SpineWand, Accutherm, and TransDiscal electrodes.
One important scope limitation: disc decompression or nucleoplasty procedures that do not use a radiofrequency energy source or electrothermal energy—such as the disc decompressor procedure or laser procedures—fall outside this NCD's scope entirely. If your team is billing for those, NCD 324 does not govern them.
Understanding What TIPs Are — and Why CMS Excludes Them
TIPs involve the insertion of a catheter or probe into the spinal disc under fluoroscopic guidance. The goal is to apply heat and/or disruption within the disc to relieve low back pain. The techniques vary—single or multiple probes, flexible or rigid designs, placement in the nucleus, nuclear-annular junction, or annulus—but they share a common therapeutic intent: coagulation or decompression of disc material.
CMS's position is that the clinical evidence does not support these procedures as reasonable and necessary for Medicare beneficiaries. The agency reviewed this NCD in September 2008 and found insufficient evidence to justify coverage. The 2026 modification does not change the underlying clinical rationale—the noncoverage determination remains intact.
For billing managers, this means there is no pathway to Medicare coverage for these procedures based on medical necessity criteria, because CMS has not established any covered indications. There is nothing to document, no prior authorization process to pursue, and no appeal pathway based on medical necessity arguments when the NCD itself forecloses coverage.
CMS Coverage vs. Noncoverage at a Glance
| Coverage Status | Detail |
|---|---|
| Nationally Covered Indications | None |
| Nationally Non-Covered Indications | All TIPs for treatment of low back pain, effective September 29, 2008 (confirmed in 2026 modification) |
| Scope Exclusions | Disc decompression/nucleoplasty without radiofrequency or electrothermal energy (e.g., disc decompressor, laser procedures) |
| Prior Authorization | Not applicable — procedure is noncovered |
| Experimental Designation | Not explicitly labeled as experimental; classified as not reasonable and necessary |
| 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 data for NCD 324 does not list specific CPT or HCPCS codes. CMS has not published a corresponding code list with this NCD modification. Billing teams should consult the applicable Medicare Claims Processing transmittal—Transmittal R1646CP—for claims processing instructions and reach out to their Medicare Administrative Contractor (MAC) for guidance on which specific procedure codes are subject to the noncoverage determination in their jurisdiction.
There are no ICD-10-CM diagnosis codes listed in the policy data that would create a covered pathway. The NCD applies regardless of diagnosis coding.
What Your Billing Team Should Do
| # | Action Item |
|---|---|
| 1 | Audit any pending or planned TIP claims immediately. If your practice performs procedures that fall within the scope of NCD 324—particularly IDET, IDB, PIRFT, PDD, or radiofrequency annuloplasty—pull those claims now. Any Medicare claim for these services will be denied under NCD 324, and submitting them creates compliance exposure. |
| 2 | Contact your Medicare Administrative Contractor (MAC) within the next 30 days to confirm which CPT or HCPCS codes they apply NCD 324 to in your jurisdiction. Because CMS has not attached specific codes to this policy, your MAC's local claims processing rules determine how denials are triggered. Get that list in writing. |
| 3 | Update your denial management and appeals workflows by March 12, 2026. Remove any appeal pathways for TIP denials that are based on medical necessity arguments—those appeals will not succeed against an NCD. Instead, train your team to recognize NCD 324 denial reason codes on Remittance Advice and to route them to appropriate write-off or patient liability processes. |
| 4 | Issue Advance Beneficiary Notices of Noncoverage (ABNs) where applicable. If a patient requests a TIP procedure and your physician believes it is medically appropriate, you may still perform it—but you must issue a valid ABN before the service so the Medicare beneficiary can make an informed financial decision. Failure to issue an ABN makes the provider liable for the cost. |
| 5 | Review any contracts with ASC or hospital outpatient departments where TIPs are performed. If those facilities are billing Medicare for these procedures, your organization may share compliance risk. Confirm that facility billing teams are aligned with NCD 324. |
Get the Full Picture
Track this policy across versions, search 1,500+ policies by CPT code, and get real-time alerts when any payer changes coverage.