CMS Retired NCD 326 for Surgery for Diabetes — What Billing Teams Need to Know in 2026
TL;DR: The Centers for Medicare & Medicaid Services modified NCD 326 (Surgery for Diabetes) on January 9, 2026 — this section is retired and has been fully incorporated into NCD 100.1 since September 24, 2013. If your team still references NCD 326 as a standalone policy for diabetes surgery billing, you're working from the wrong document.
The retirement of NCD 326 isn't a new clinical decision — it happened over a decade ago. But CMS formally updated this entry in the NCD Manual on March 9, 2023, with an effective date of April 10, 2023, and the January 9, 2026 update reflects the current state of the policy record. Any coverage determination for surgery for diabetes now lives entirely under NCD 100.1. If your billing guidelines or internal coverage policy references still point to NCD 326 as an active standalone section, that's a problem worth fixing now.
This policy does not list specific CPT, HCPCS, or ICD-10 codes. Applicable procedure codes for diabetes surgery should be verified against NCD 100.1 directly.
Quick-Reference Table
| Field | Detail |
|---|---|
| Payer | CMS (Centers for Medicare & Medicaid Services) |
| Policy | Surgery for Diabetes — RETIRED |
| Policy Code | NCD 326 |
| Change Type | Modified (Retirement confirmed) |
| Effective Date | 2026-01-09 (original retirement: April 10, 2023) |
| Impact Level | Low for most teams — Medium if your internal docs still reference NCD 326 |
| Specialties Affected | General surgery, bariatric surgery, endocrinology billing teams, diabetes care programs |
| Key Action | Remove NCD 326 references from internal coverage policy docs and point all diabetes surgery billing to NCD 100.1 |
CMS Surgery for Diabetes Coverage Criteria and Medical Necessity Requirements 2026
Here's the real situation: NCD 326 no longer governs surgery for diabetes coverage policy on its own. CMS removed section 100.14 from the NCD Manual and merged it into NCD 100.1 effective September 24, 2013. The January 9, 2026 record reflects a retired section — not an active coverage framework.
That means any medical necessity determination for surgery related to diabetes runs through NCD 100.1. If you're asking whether a specific diabetes surgery procedure meets Medicare's medical necessity standard, NCD 326 gives you no answer. You have to go to NCD 100.1.
This matters for prior authorization workflows too. If your team built any prior authorization checklists or coverage policy templates that cite "NCD 326" as the controlling authority, those documents are outdated. A claim denial based on incorrect policy citation is avoidable — and this is one of the easier fixes.
The CMS surgery for diabetes coverage policy has been consolidated for over 12 years. The 2026 record update is essentially a housekeeping confirmation that section 100.14 is gone and won't be coming back as a standalone rule.
Coverage Indications at a Glance
Given that NCD 326 is fully retired, there are no active standalone coverage indications to list under this policy number. The table below reflects the current state of the record.
| Indication | Status | Relevant Codes | Notes |
|---|---|---|---|
| Surgery for Diabetes (all indications) | Retired — refer to NCD 100.1 | See NCD 100.1 | Section 100.14 removed from NCD Manual; effective September 24, 2013 |
| Prior Authorization requirements under NCD 326 | N/A — policy retired | N/A | Any prior auth requirements now governed by NCD 100.1 |
CMS Surgery for Diabetes Billing Guidelines and Action Items 2026
The practical lift here is small — but skipping it costs you. Here's what to do before you close out this policy change.
| # | Action Item |
|---|---|
| 1 | Pull every internal document that references NCD 326. Check your billing guidelines, payer-specific coverage policy summaries, prior authorization templates, and denial appeal letters. If any of them cite NCD 326 as an active standalone NCD, update the reference to NCD 100.1 immediately. |
| 2 | Update your charge capture references for diabetes surgery procedures. Billing for surgery for diabetes under Medicare requires alignment with NCD 100.1, not NCD 326. Any charge capture workflows or coverage checklists that route diabetes surgery claims through a separate NCD 326 review step should be corrected. |
| 3 | Audit recent claim denials tied to diabetes surgery. If you've received a claim denial citing NCD 326 coverage limitations in the past year, review whether the denial logic should have been evaluated under NCD 100.1 instead. This could affect your appeal strategy. |
| 4 | Brief your medical necessity reviewers. Anyone on your team who performs medical necessity reviews for diabetes surgery procedures should know that NCD 100.1 is the controlling document. Reimbursement determinations that rely on the wrong NCD are a liability in audit situations. |
| 5 | Check with your Medicare Administrative Contractor (MAC) for regional guidance. MACs sometimes publish local coverage determination (LCD) policies that layer on top of national CMS coverage policy. If your MAC has an LCD related to diabetes surgery, verify it references NCD 100.1 — not the retired NCD 326 section. |
| 6 | If your compliance officer or billing consultant built any compliance monitoring workflows around NCD 326, loop them in. The effective date of the retirement is April 10, 2023 — but the January 9, 2026 record update is a good trigger to confirm those workflows have been corrected. If you're not sure how this applies to your billing mix, ask your compliance officer before assuming you're covered. |
| 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 |
CPT, HCPCS, and ICD-10 Codes for Surgery for Diabetes Under NCD 326
This policy does not list specific CPT, HCPCS, or ICD-10 codes. NCD 326 is retired. Applicable codes for surgery for diabetes billing should be sourced directly from NCD 100.1.
Do not use this page to build a code list for diabetes surgery claims. Any codes listed here would be fabricated — and fabricated code references in billing guidelines create real exposure.
The right move: pull the current version of NCD 100.1 from CMS directly and verify the applicable procedure codes with your billing consultant or coding team. If your team doesn't have a current NCD 100.1 code reference on file, that's the gap to close.
What This Retirement Actually Means for Your Revenue Cycle
Let's be direct about the stakes. A retired NCD is not a coverage gap — it's an administrative consolidation. Medicare didn't stop covering surgery for diabetes when it retired NCD 326. It moved the coverage policy into a different section of the NCD Manual.
The risk isn't a claim denial because the procedure lost coverage. The risk is operational: outdated internal references, misfiled appeals, and prior authorization requests built on stale documentation. Those are the failure points that cost billing teams time and money.
For most practices, the reimbursement exposure here is indirect. You won't lose a claim because NCD 326 exists as a retired record. You might lose a claim — or an appeal — because someone on your team cited the wrong policy number in a medical necessity determination letter.
The diabetes surgery billing implications run through NCD 100.1, full stop. Everything else is cleanup.
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