CMS Retired NCD 351 for Diagnostic Pap Smears — What Billing Teams Need to Know in 2026

TL;DR: The Centers for Medicare & Medicaid Services retired NCD 351, which previously governed Medicare diagnostic Pap smear coverage, effective April 10, 2023. The retirement redirects all coverage authority to NCD 190.2. If your billing team is still referencing NCD 351 as a standalone policy, stop — it no longer exists as independent guidance.

This change was issued on March 9, 2023, with an effective date of April 10, 2023, and implementation on April 10, 2023. The CMS policy database updated this record on January 9, 2026. This update does not list specific CPT or HCPCS codes — coverage for diagnostic Pap smears now falls entirely under the framework at NCD 190.2. If your team bills diagnostic Pap smears to Medicare, your reference document has changed.

Quick-Reference Table

CMS Diagnostic Pap Smear Coverage Criteria and Medical Necessity Requirements 2026

This is where things get nuanced — and where billing teams sometimes get tripped up.

NCD 351 no longer sets coverage criteria. It defers entirely to NCD 190.2, which is the National Coverage Determination governing gynecological procedures under Medicare. The CMS diagnostic Pap smear coverage policy has not been eliminated. It has been consolidated.

Medical necessity determinations for diagnostic Pap smears now live under NCD 190.2. If your team is documenting medical necessity for a diagnostic Pap smear claim, your supporting criteria must align with what NCD 190.2 requires — not what any internal reference to NCD 351 may have captured from older versions.

The practical problem: many billing teams, compliance manuals, and charge capture workflows still cite NCD 351 as a live policy reference. That creates a documentation and audit risk. If a claim is pulled for review and your internal guidelines point to a retired NCD, that's a flag — even if the claim itself is correct.

Pull your current payer policy references and confirm that NCD 351 has been replaced with NCD 190.2 in every place it appears. This includes charge capture tools, billing guidelines documents, payer policy binders, and any staff training materials.

The NCD 351 CMS system record still exists in the Medicare Coverage Database, but it functions as a tombstone. It points to NCD 190.2 and carries no independent coverage criteria. Do not treat the existence of the record as evidence that the policy is still active guidance.

Prior authorization is not explicitly addressed in this retirement notice. Because NCD 190.2 is now the governing authority, your team should review whether prior authorization requirements apply under NCD 190.2 for any diagnostic Pap smear services you bill to Medicare.

Coverage Indications at a Glance

The policy data for NCD 351 does not include specific CPT, HCPCS, or ICD-10 codes. Coverage status at the code level is now governed by NCD 190.2.

CMS Diagnostic Pap Smear Billing Guidelines and Action Items 2026

Here is what your billing team needs to do. These are not suggestions.

1. Replace NCD 351 references with NCD 190.2 in all internal documentation.
Every place your billing team cites NCD 351 — policy binders, charge capture workflows, training decks, payer reference sheets — update it to NCD 190.2. The effective date for this retirement was April 10, 2023. If this has not happened yet, it is overdue.

2. Pull your diagnostic Pap smear claim denial history and check for mismatched policy citations.
If your team has cited NCD 351 as supporting authority on any claim submitted after April 10, 2023, review those claims. A citation to a retired NCD is not automatically a denial trigger, but it is a documentation weakness. Clean that up before an audit surfaces it.

3. Review NCD 190.2 in full for current medical necessity criteria.
The retirement of NCD 351 transferred all coverage authority. That means NCD 190.2 now carries the full weight of Medicare's position on diagnostic Pap smear reimbursement. Read it. Your coding and clinical documentation should reflect its criteria, not assumptions carried over from NCD 351.

4. Audit your payer policy management process.
This retirement was issued in March 2023 and took effect April 10, 2023. If your team is discovering it now because of the January 9, 2026 database update, that is a gap in your policy tracking. Build a process that catches NCD and LCD changes within 30 days of issuance — not 36 months later.

5. Confirm correct claim submission for diagnostic vs. screening Pap smears.
Diagnostic Pap smear billing and screening Pap smear billing operate under different Medicare frameworks. Do not conflate them. If your team is billing diagnostic Pap smears and also billing preventive Pap smears, verify that each claim type references the correct governing policy and uses appropriate diagnosis coding to support medical necessity.

6. Loop in your compliance officer if NCD 351 appears in any active compliance documentation.
If NCD 351 is cited in your practice's compliance plan, billing guidelines, or audit protocols, flag it now. Your compliance officer needs to know a retired policy is appearing as active guidance. This is exactly the kind of documentation drift that creates exposure during a Medicare audit.

CPT, HCPCS, and ICD-10 Codes for Diagnostic Pap Smears Under NCD 351

The policy data for NCD 351 does not list specific CPT, HCPCS, or ICD-10 codes. CMS did not include a code set in this retirement notice.

This is intentional. NCD 351 was retired and redirected — it transfers code-level coverage authority to NCD 190.2. Applicable codes for diagnostic Pap smear billing now appear under NCD 190.2.

Do not infer that the absence of codes in NCD 351 means diagnostic Pap smear services are uncovered. It means the code list lives elsewhere. Go to NCD 190.2 for applicable billing codes, coverage conditions, and reimbursement guidance.

If you are unsure which codes your team should use for diagnostic Pap smear claims under Medicare, review NCD 190.2 directly or consult with your Medicare Administrative Contractor. MAC-level guidance sometimes adds specificity beyond what a National Coverage Determination provides. A local coverage determination from your MAC may also be relevant, depending on your region.

What This Retirement Really Means for Your Revenue Cycle

Here is the honest take: this retirement is administrative consolidation, not a substantive coverage change. CMS is not pulling back on diagnostic Pap smear coverage. It is cleaning up its policy structure by eliminating a redundant NCD.

The real risk is not the retirement itself. The risk is inertia — billing teams and compliance programs that have not updated their references and are still treating NCD 351 as live guidance.

A retired NCD still shows up in the Medicare Coverage Database. That makes it easy to find and easy to misread as active. The database entry for NCD 351 does not disappear. It stays there, labeled "retired," pointing to NCD 190.2. If someone on your team pulls it up without reading carefully, they may not notice the retirement status.

Build this into your next team training session. Show your billing staff what a retired NCD record looks like in the CMS Coverage Database. Teach them to check the status field before treating any NCD as active guidance.

The financial exposure here is low on a per-claim basis. But documentation drift — citing retired policies, using outdated medical necessity criteria, missing MAC-level LCDs that modify NCD 190.2 — compounds over time. Fix it now while it is simple.