CMS NCD 326 Surgery for Diabetes Policy Retired: What Billing Teams Need to Know

CMS has formally retired NCD 326 (Policy Key: 326-v3), the standalone National Coverage Determination for Surgery for Diabetes. This modification, reflected in the March 2026 policy record, confirms that section 100.14 of the NCD Manual was removed and folded into NCD 100.1 back in September 2013 — but many billing teams are still referencing the old policy code in their workflows. If your practice or revenue cycle team hasn't updated internal reference materials to point to NCD 100.1, now is the time to do it.

What CMS NCD 326 Was — and Why It's Been Retired

NCD 326, formally titled "Surgery for Diabetes" and housed under section 100.14 of the CMS NCD Manual, served as a discrete coverage policy addressing surgical interventions in the context of diabetes management. CMS retired section 100.14 effective September 24, 2013, consolidating its guidance into NCD 100.1.

The March 2026 policy record for NCD 326 (326-v3) is essentially a housekeeping update — a formal acknowledgment in the policy system that the old standalone entry no longer functions as an active coverage authority. The substantive clinical and coverage criteria have not been deleted; they've been absorbed into NCD 100.1, which serves as the governing NCD for this clinical area.

This matters for billing teams because policy management systems, payer portals, and internal documentation sometimes retain legacy references. A claim or prior authorization request that cites NCD 326 as its coverage basis could create confusion or documentation mismatches during audits.

Where Coverage Policy Now Lives: NCD 100.1

All coverage guidance previously contained in NCD 326 (section 100.14) is now incorporated into NCD 100.1. Billing and clinical documentation teams should direct any questions about Medicare coverage for diabetes-related surgical procedures to that NCD.

The Centers for Medicare & Medicaid Services made this consolidation to reduce policy fragmentation — a known source of billing errors when teams are working across multiple NCD references to determine coverage for a single patient encounter. With the retirement of 326-v3 now reflected in the public policy record, there's no remaining ambiguity: NCD 100.1 is the authoritative source.

If your organization has any internal coverage checklists, payer policy binders, or electronic health record (EHR) billing rules that reference NCD 326 by code or by the "100.14" section designation, those references should be updated immediately.

Impact on Bariatric and Metabolic Surgery Billing

Practices performing bariatric surgery, metabolic surgery, or other surgical interventions with diabetes-related indications under Medicare should be particularly attentive. This policy category falls under the Physicians' Services benefit category, meaning physician billing — not just facility billing — is affected.

The retirement of NCD 326 does not change whether procedures are covered or non-covered under Medicare. What it changes is the reference trail. When submitting claims, appealing denials, or responding to medical necessity audits, citing a retired NCD code instead of the active governing NCD can raise questions about documentation accuracy.

Revenue cycle directors should verify that denial management workflows, appeal letter templates, and medical necessity documentation tools are cross-referenced to NCD 100.1 — not the retired 326-v3 entry.

Prior Authorization and Medical Necessity Considerations

The NCD 326 policy document does not specify prior authorization requirements in its retired form, and no new prior auth rules are introduced by this modification. However, that doesn't mean prior authorization is off the table — local coverage determinations (LCDs) from Medicare Administrative Contractors (MACs) may impose their own prior auth or documentation requirements for diabetes-related surgeries billed under Part B.

Billing teams should check with their specific MAC for any LCD-level requirements that govern surgical diabetes procedures in their jurisdiction. NCD 100.1 sets the national floor; MACs can be more restrictive.

Medical necessity documentation should be aligned with the criteria outlined in NCD 100.1, not NCD 326. Any letter of medical necessity, operative report summary, or supporting documentation package referencing the old section 100.14 should be updated to reflect the current policy framework.

Affected Codes

The NCD 326 (326-v3) policy document does not list specific CPT, HCPCS Level II, or ICD-10-CM codes. No code table appears in the policy record for this retired NCD.

For applicable procedure and diagnosis codes associated with diabetes-related surgical coverage under Medicare, billing teams should reference NCD 100.1 directly, along with any relevant LCD published by their MAC. Your MAC's website and the CMS Coverage Database are the authoritative sources for code-level detail under this policy area.

What Your Billing Team Should Do