TL;DR: The Centers for Medicare & Medicaid Services reaffirmed NCD 337, its national coverage determination for the collagen meniscus implant (CMI), with a policy record update dated January 9, 2026. The bottom line hasn't changed — Medicare does not cover the collagen meniscus implant — but this update is a signal to audit your charge capture and claims processes now.
The CMS collagen meniscus implant coverage policy has been non-covered since May 25, 2010. The NCD 337 Medicare determination concludes that the CMI does not improve health outcomes and fails the "reasonable and necessary" standard under Section 1862(a)(1)(A) of the Social Security Act. This policy applies across all Medicare claims for meniscal injury or tear treatment using a collagen scaffold or Menaflex™ implant. No specific CPT or HCPCS codes are listed in the policy document itself.
Quick-Reference Table
| Field | Detail |
|---|---|
| Payer | CMS (Centers for Medicare & Medicaid Services) |
| Policy | Collagen Meniscus Implant — NCD 337 |
| Policy Code | NCD 337 |
| Change Type | Modified (record update) |
| Effective Date | 2026-01-09 |
| Impact Level | Medium — non-coverage confirmed, denial risk is real if billed |
| Specialties Affected | Orthopedic surgery, sports medicine, ambulatory surgical centers |
| Key Action | Confirm the collagen meniscus implant is flagged as non-covered in your charge capture system before billing any Medicare claim for meniscal repair |
CMS Collagen Meniscus Implant Coverage Criteria and Medical Necessity Requirements 2026
The real issue here is simple: there are no covered indications. The CMS collagen meniscus implant coverage policy under NCD 337 is a blanket non-coverage determination. There is no path to medical necessity approval for Medicare patients.
The Centers for Medicare & Medicaid Services reviewed the evidence and concluded in May 2010 that the collagen meniscus implant does not improve health outcomes. That conclusion has not changed. The January 9, 2026 policy update doesn't introduce new covered criteria — it confirms the existing non-coverage status.
For billing teams, this means prior authorization is irrelevant here. There is no prior authorization process to invoke, no exception pathway, and no appeals route built on medical necessity arguments that will reverse the NCD. A national coverage determination is the ceiling. Medicare Administrative Contractors and local coverage determinations cannot override it to create coverage.
The collagen meniscus implant — also called a collagen scaffold, CMI, or Menaflex™ implant in the clinical literature — is used to fill meniscal defects after partial meniscectomy. It attaches to the remaining meniscal rim and acts as a tissue scaffold. Medicare's position is that the evidence doesn't support this approach as reasonable and necessary, regardless of how the procedure is documented clinically.
If your orthopedic or sports medicine practice performs partial meniscectomy procedures and a surgeon wants to add a CMI, stop before you bill Medicare. The implant portion is non-covered. Full stop.
CMS Collagen Meniscus Implant Exclusions and Non-Covered Indications
This section is the entire policy. NCD 337 exists to define one thing: the collagen meniscus implant is not covered by Medicare.
The effective date of the non-coverage determination is May 25, 2010. Any claim for a collagen meniscus implant procedure billed to Medicare with dates of service on or after that date is subject to denial. The 2026 policy record update doesn't soften or narrow that position.
A few points worth calling out for your billing team:
The policy explicitly states the CMI is manufactured from bovine collagen. This distinguishes it from a meniscus transplant, which uses a cadaveric donor meniscus. CMS makes this distinction in the policy text. The meniscus transplant is a separate procedure and is not addressed under NCD 337. If your practice performs meniscus transplants, those claims fall under different coverage rules — don't conflate the two when coding.
The CMI requires a meniscal rim for attachment and is placed arthroscopically with an additional incision. These procedural details matter for coding the associated arthroscopic work. The arthroscopic procedure itself may still be billable — the non-coverage applies specifically to the collagen meniscus implant, not to arthroscopy or partial meniscectomy as standalone procedures.
If you're unsure how to separate the implant cost from the surgical facility and professional fees on a claim, talk to your compliance officer before submitting anything to Medicare.
Coverage Indications at a Glance
| Indication | Status | Relevant Codes | Notes |
|---|---|---|---|
| Collagen meniscus implant for meniscal injury/tear (partial meniscectomy defect) | Not Covered | No specific codes listed in NCD 337 | Non-covered effective May 25, 2010. No exceptions. Applies to all Medicare claims. |
| Collagen scaffold (CMI/Menaflex™) placed arthroscopically | Not Covered | No specific codes listed in NCD 337 | Same determination. Clinical documentation of the procedure does not create a coverage pathway. |
| Meniscus transplant (cadaveric donor) | Not addressed by NCD 337 | Separate policy applies | Do not bill under NCD 337 guidance. Confirm coverage under applicable LCD or NCD for transplant procedures. |
CMS Collagen Meniscus Implant Billing Guidelines and Action Items 2026
Here's what your billing team should do right now, before January 9, 2026 and after.
| # | Action Item |
|---|---|
| 1 | Audit your charge master and charge capture system for any CMI-related line items. If you have a charge code tied to the collagen meniscus implant, flag it as Medicare non-covered. Any claim that goes out with this procedure billed to Medicare is a guaranteed claim denial and potential compliance exposure. |
| 2 | Confirm you're not bundling the CMI cost into arthroscopy fees to obscure it. The arthroscopic procedure — partial meniscectomy, debridement — may be separately billable. The implant is not. Bundling non-covered items into covered procedure fees is a billing risk you don't want under a Medicare audit. |
| 3 | Separate your meniscus transplant workflow from your CMI workflow. NCD 337 doesn't cover meniscus transplants — meaning they're not addressed here at all. If your practice does cadaveric meniscus transplants, those need their own coverage analysis. Don't use NCD 337 as your reference for transplant reimbursement decisions. |
| 4 | Update your ABN (Advance Beneficiary Notice) protocol. If a Medicare patient and their surgeon want to proceed with a CMI despite non-coverage, you need a properly executed ABN before the procedure. This gives the patient notice that Medicare won't pay and shifts financial responsibility. Without it, you can't bill the patient either. |
| 5 | Document the clinical rationale for the associated arthroscopy separately. Since partial meniscectomy and arthroscopic work may be covered independent of the CMI, your documentation needs to support those procedures on their own terms. Don't let the non-covered implant contaminate the documentation for the covered surgical components. |
| 6 | Brief your orthopedic and sports medicine billing staff on the distinction between CMI and meniscus transplant. These are different procedures with different coverage rules. Confusion between them is a real source of incorrect claims. A short internal training note tied to this NCD 337 update is worth the 20 minutes. |
If you have a high volume of knee arthroscopy claims and aren't certain how this NCD applies to your specific code mix and documentation practices, loop in your compliance officer or a billing consultant before the effective date of January 9, 2026.
| 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 Collagen Meniscus Implant Under NCD 337
The NCD 337 policy document does not list specific CPT, HCPCS, or ICD-10 codes. This is worth paying attention to.
When CMS issues a national coverage determination without associated billing codes, it means the non-coverage applies to the procedure and the device — not to a specific code set. Your Medicare Administrative Contractor may provide additional claims processing instructions that reference specific codes. The transmittal referenced in the policy (TN 1977, Medicare Claims Processing) is your next stop for code-level guidance.
What This Means for Collagen Meniscus Implant Billing
Because NCD 337 doesn't enumerate codes, you need to approach this differently than a standard code-level denial. Any claim for a service that involves a collagen meniscus implant — regardless of how it's coded — falls under this non-coverage determination. The absence of a code list is not a loophole.
Work with your MAC to confirm how they expect CMI-related claims to be submitted or rejected. If your MAC has a local coverage determination or claims processing article that references specific CPT codes for knee arthroscopy with scaffold implantation, use that as your code-level reference for collagen meniscus implant billing.
There are no covered CPT or HCPCS codes to list under NCD 337. There are no ICD-10 codes listed in the policy. Do not assume that a specific diagnosis code changes the coverage status — the non-coverage is absolute under this NCD.
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