Thermal Intradiscal Procedures (TIPs) — NCD 324 | CMS Coverage Update

TL;DR: The Centers for Medicare & Medicaid Services updated NCD 324 governing thermal intradiscal procedures (TIPs), with a policy review date of January 9, 2026. The CMS TIPs coverage policy has not changed its coverage position — these procedures remain nationally non-covered for Medicare — but billing teams need to know exactly what falls under this NCD and why claims will deny.

CMS NCD 324 Medicare covers thermal intradiscal procedures, or TIPs, a category that includes intradiscal electrothermal therapy (IDET), radiofrequency annuloplasty (RA), intradiscal biacuplasty (IDB), and related percutaneous spinal disc techniques. The Centers for Medicare & Medicaid Services determined these procedures are not reasonable and necessary for the treatment of low back pain — effective for services on or after September 29, 2008 — and that position holds through this 2026 review. This policy does not list specific CPT or HCPCS codes, which creates real risk for billing teams who don't know where the scope of this NCD begins and ends.

Quick-Reference Table

CMS Thermal Intradiscal Procedure Coverage Criteria and Medical Necessity Requirements 2026

The CMS TIPs coverage policy has one core finding: there are no nationally covered indications. None. CMS reviewed TIPs in 2008 and concluded that these procedures do not meet the Medicare medical necessity standard — meaning they are not "reasonable and necessary" under Section 1862(a)(1)(A) of the Social Security Act.

That standard is the bedrock of Medicare reimbursement. For a service to be covered, it must be reasonable and necessary for the diagnosis or treatment of illness or injury. CMS found no sufficient clinical evidence that TIPs meet that bar for low back pain treatment. The 2026 policy review didn't change that determination.

The scope of this NCD is wider than many billing teams realize. It covers any percutaneous intradiscal technique that uses radiofrequency energy or electrothermal energy to apply or create heat or disruption within the disc. The intent — whether that's coagulation, decompression, sealing annular tears, or destroying nociceptors — doesn't matter. If it fits that description, it's non-covered under NCD 324.

Prior authorization from Medicare doesn't apply here in the traditional sense. There is nothing to authorize. CMS has made a national coverage determination that these procedures lack medical necessity support. No prior auth pathway exists to get TIPs covered under standard Medicare fee-for-service.

CMS Thermal Intradiscal Procedure Exclusions and Non-Covered Indications

This is where billing teams need to pay close attention to scope. The NCD covers a broad set of techniques. Common names that fall under this non-coverage determination include:

These procedures are also sometimes identified by the device used rather than the technique name. SpineCath, discTRODE, SpineWand, Accutherm, and TransDiscal electrodes are all explicitly referenced in the NCD. If your documentation uses device names rather than procedure names, the NCD still applies.

One important carve-out: the NCD does not cover disc decompression or nucleoplasty procedures that do NOT use radiofrequency or electrothermal energy. Laser procedures and mechanical disc decompressor procedures are outside the scope of NCD 324. That distinction matters for claim denial analysis — if your procedure uses neither radiofrequency nor electrothermal energy, this NCD is not the reason for your denial.

The real issue here is scope creep in documentation. Providers sometimes document a procedure using a device brand name or a technique synonym without realizing it maps directly to a non-covered NCD category. Your billing team needs to recognize all the aliases for these procedures.

Coverage Indications at a Glance

CMS Thermal Intradiscal Procedure Billing Guidelines and Action Items 2026

This NCD has been in place since 2008, but the January 9, 2026 review date means it's active and enforceable today. If your practice performs any TIPs for Medicare patients, here's what your billing team needs to do now.

CPT, HCPCS, and ICD-10 Codes for Thermal Intradiscal Procedures Under NCD 324

A Note on Code Availability

NCD 324 does not list specific CPT or HCPCS codes. This is not unusual for older NCDs, but it creates a real challenge for TIPs billing. You cannot simply maintain a code-level list and flag it in your charge master. Instead, you need to build coverage logic around the procedure description and technique names listed in the NCD.

The absence of specific codes in this policy is actually the main billing risk here. Unlike an NCD that says "CPT XXXXX is non-covered," NCD 324 relies on clinical and procedural descriptions. That means the determination of whether a claim falls under this NCD requires someone with clinical knowledge to evaluate whether the procedure used radiofrequency or electrothermal energy in an intradiscal application.

What This Means for Your Charge Capture

Work with your billing consultant or compliance officer to map your current TIPs procedure codes — whatever internal charge codes or CPT codes your practice uses — to the NCD 324 description. Once those codes are identified, flag them as Medicare non-covered in your charge capture system.

If you're unsure which codes in your system map to TIPs, pull your pain management and spine surgery charges for the past 12 months and review procedure descriptions against the technique list in the NCD. Any procedure that used radiofrequency or electrothermal energy inside a spinal disc is in scope.

The transmittal reference for this NCD is TN 1646, available through CMS's Medicare Claims Processing transmittals. Your MAC's claims processing instructions may have additional guidance tied to that transmittal.