CMS Updates Coverage Policy for Ocular Photodynamic Therapy (NCD 349): What Ophthalmology Billing Teams Need to Know

CMS has issued a modification to National Coverage Determination (NCD) 349, which governs Medicare coverage of Ocular Photodynamic Therapy (OPT) with verteporfin for age-related macular degeneration (AMD). Effective March 12, 2026, this update clarifies and consolidates the coverage framework that has evolved through multiple CMS decisions dating back to 2001—including which AMD subtypes qualify, what diagnostic documentation is required, and which indications remain explicitly non-covered. If your practice bills Medicare for retinal disease treatment, this policy deserves a careful read before your next claim goes out.

Field Detail
Payer CMS (Centers for Medicare & Medicaid Services)
Policy Ocular Photodynamic Therapy (OPT)
Policy Code NCD 349
Change Type Modified
Effective Date 2026-03-12
Impact Level Medium
Specialties Affected Ophthalmology, Retinal Surgery, Optometry (billing), RCM teams serving eye care practices
Key Action Audit active AMD claims to confirm CNV lesion type, size, and progression documentation align with the updated covered indications before submission.

What CMS NCD 349 Actually Covers: OPT with Verteporfin and AMD Indications

OPT is not a standalone procedure under Medicare. The Centers for Medicare & Medicaid Services makes clear that OPT is only covered when used in conjunction with verteporfin, the IV photosensitizing drug administered before laser exposure. If your documentation doesn't reflect verteporfin use, coverage does not apply—full stop.

The policy was first implemented July 1, 2001, with a narrow indication: neovascular AMD with predominantly classic subfoveal choroidal neovascularization (CNV) lesions, where classic CNV occupies 50% or more of the entire lesion area. That threshold was established by fluorescein angiogram (FA) at the initial visit.

As of April 1, 2004, CMS significantly expanded the covered indications—and the March 2026 modification carries those expanded criteria forward. Billing teams should treat these as the operative coverage rules now in effect.


CMS Medicare Coverage Criteria for OPT: Three Covered AMD Indications

Under NCD 349, OPT with verteporfin is nationally covered for three distinct AMD presentations. Two of them come with additional medical necessity requirements your documentation must support.

Indication 1 — Predominantly Classic Subfoveal CNV

Coverage applies when classic CNV occupies ≥ 50% of the total lesion area at the initial visit, confirmed by FA. For subsequent treatment visits, CMS accepts either:

#Covered Indication
1An FA (effective April 1, 2004), or
2Optical coherence tomography (OCT) (effective April 3, 2013)

There are no requirements related to visual acuity, lesion size, or number of re-treatments for predominantly classic lesions. This is the most permissive of the three covered presentations.

Indication 2 — Subfoveal Occult with No Classic CNV

CMS determined the evidence is adequate to cover this subtype, but only when both of the following conditions are met:

#Covered Indication
1The lesion is 4 disk areas or less in size at the time of initial treatment, or within the 3 months prior to initial treatment.
2The lesion has shown documented evidence of progression within the 3 months prior to initial treatment.

Acceptable evidence of progression includes at least one of:

#Covered Indication
1Deterioration of visual acuity (at least five letters on a standard eye examination chart)
2Lesion growth (increase of at least one disk area)
3Appearance of blood associated with the lesion

Indication 3 — Subfoveal Minimally Classic CNV

This applies when classic CNV occupies less than 50% of the entire lesion area. The same two conditions above—lesion size of 4 disk areas or less, plus documented progression within the prior 3 months—must be satisfied.

Both Indications 2 and 3 require tight, time-stamped documentation. If your chart doesn't reflect lesion size and progression evidence within that 90-day window, expect a denial.


CMS Non-Covered OPT Indications Under NCD 349

CMS is equally explicit about what is not covered, and these exclusions are national—no local contractor discretion applies. Under Section C of NCD 349, OPT with verteporfin for AMD is not covered in the following situations:

Any AMD indication not explicitly addressed by CMS also defaults to non-covered. Do not submit claims for unlisted AMD subtypes expecting favorable adjudication.


Other Ocular Indications: Local Coverage Contractor Discretion Applies

NCD 349 does not govern OPT with verteporfin for non-AMD ocular conditions. Specifically, pathologic myopia and presumed ocular histoplasmosis syndrome are explicitly carved out and remain eligible for Local Coverage Determinations (LCDs) at individual Medicare Administrative Contractor (MAC) discretion.

If your practice treats these conditions with OPT, you'll need to check your MAC's applicable LCD rather than relying on NCD 349. Coverage and documentation requirements will vary by region.


Sample Version Diff Line-by-line changes
Previous VersionCurrent Version
Coverage is considered experimental and investigational for all indicationsCoverage is considered medically necessary when specific criteria are met
Prior authorization is not requiredPrior authorization is required for initial treatment
Documentation must include clinical historyDocumentation must include clinical history
Re-review every 24 monthsRe-review every 12 months with updated clinical documentation

Affected Codes

The policy document for NCD 349 does not list specific CPT or HCPCS codes, and no ICD-10-CM codes are enumerated in the source data. Practices should consult their MAC's billing guidance and the CMS HCPCS database to identify the appropriate procedure codes for verteporfin infusion and the OPT laser procedure. ICD-10-CM codes for AMD subtypes (wet/neovascular vs. dry, with laterality) should be selected based on the specific covered indication being billed.


This policy is now in effect (since 2026-03-12). Verify your claims match the updated criteria above.

What Your Billing Team Should Do

#Action Item
1

Audit your AMD documentation workflow now—before March 12, 2026. Pull a sample of recent OPT claims and verify that each chart clearly identifies the CNV subtype (predominantly classic, minimally classic, or occult with no classic) and that the initial FA or OCT is present and dated. If charts are missing this language, work with clinicians to update documentation templates.

2

Build a 90-day progression checklist for Indications 2 and 3. For occult/no-classic and minimally classic CNV cases, create a structured documentation field that captures lesion size (in disk areas), visual acuity change (in letters), and any documented lesion growth or hemorrhage within the 3 months before initial treatment. This should be part of your pre-authorization and pre-billing review.

3

Flag extrafoveal, juxtafoveal, and dry AMD cases before they reach billing. Set up a claim scrubbing rule or pre-bill audit to catch AMD diagnoses that correspond to non-covered indications. A denial on these cases is entirely avoidable with front-end controls.

+ 2 more action items

Enter your email to unlock all tables — 100% free

Unlocks every table on this page. Free weekly digest included. By subscribing you agree to our Terms and Privacy Policy.

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.

🔍 Search by any code 🔔 Real-time alerts 📊 Line-by-line diffs ⏰ Deadline tracking
Get Full Access → $99/mo · 14-day money-back guarantee