CMS NCD 47 Decubitus Ulcer Treatment Coverage: What Changes in 2026
CMS has modified National Coverage Determination (NCD) 47, which governs Medicare coverage for the treatment of decubitus ulcers. This update, effective March 12, 2026, reaffirms hydrotherapy (whirlpool) as a covered service while drawing a clear line around non-covered treatments whose safety and effectiveness have not been established. If your facility bills for wound care services under Medicare, this policy deserves a close read.
| Field | Detail |
|---|---|
| Payer | CMS (Medicare) |
| Policy | Treatment of Decubitus Ulcers |
| Policy Code | NCD 47 |
| Change Type | Modified |
| Effective Date | 2026-03-12 |
| Impact Level | Medium |
| Specialties Affected | Wound care, skilled nursing, physical therapy, home health, long-term care |
| Key Action | Audit current decubitus ulcer treatment protocols to confirm only covered modalities are being billed to Medicare |
What NCD 47 Covers: CMS Medicare Policy on Decubitus Ulcer Treatment
The Centers for Medicare & Medicaid Services (CMS) classifies decubitus ulcer treatment under the Physicians' Services benefit category. Under NCD 47, the foundational covered approach involves removing dead tissue from ulcer lesions and keeping them clean to promote new tissue growth — a process that can be accomplished through hydrotherapy, commonly known as whirlpool treatment.
CMS covers hydrotherapy (whirlpool) for decubitus ulcers when the treatment is deemed reasonable and necessary for the individual patient. That "reasonable and necessary" standard is the critical threshold your documentation must meet. Medical records need to support that hydrotherapy is clinically appropriate given the patient's wound status, overall condition, and care setting.
This policy falls under Physicians' Services, meaning it applies broadly across care settings where physicians or qualified non-physician practitioners are directing wound care — including outpatient wound centers, skilled nursing facilities (SNFs), and home health contexts where applicable.
What CMS Does NOT Cover Under NCD 47: Non-Covered Decubitus Ulcer Treatments
This is where billing teams need to pay close attention. NCD 47 explicitly identifies a category of decubitus ulcer treatments that are not covered under Medicare because their safety and effectiveness have not been established. CMS provides the following examples of non-covered treatment modalities:
- Ultraviolet light
- Low intensity direct current
- Topical application of oxygen
- Topical dressings with Balsam of Peru in castor oil
These are cited as examples, not an exhaustive list — meaning CMS's intent is to exclude any treatment modality that lacks established safety and effectiveness, even if it doesn't appear word-for-word in this list. If a provider is using a novel or emerging wound care approach for decubitus ulcers and billing Medicare, you need documentation that the specific modality is covered, not just that decubitus ulcer treatment broadly is covered.
Billing non-covered services to Medicare — even inadvertently — creates denial exposure and potential overpayment liability. The distinction CMS draws here is meaningful and enforceable.
Medical Necessity Documentation Requirements for Medicare Wound Care Billing
Because hydrotherapy coverage hinges on "reasonable and necessary," your documentation needs to do real work. At minimum, clinical notes supporting a covered hydrotherapy claim should address:
| # | Covered Indication |
|---|---|
| 1 | The stage and characteristics of the decubitus ulcer being treated |
| 2 | Why hydrotherapy is the appropriate modality for this patient's wound |
| 3 | The patient's response to treatment over time |
| 4 | That non-covered alternatives were not used or billed in conjunction |
CMS does not specify a prior authorization requirement within NCD 47 itself. However, that does not eliminate the possibility that your Medicare Administrative Contractor (MAC) has local coverage determination (LCD) policies that layer additional requirements on top of the NCD. Always check with your MAC for any applicable LCDs related to wound care in your jurisdiction.
| 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 |
Affected Codes
This policy does not list specific CPT or HCPCS codes. NCD 47 defines coverage at the service and clinical criteria level without enumerating procedure codes directly. Billing teams should reference their MAC's LCD guidance and the CMS Claims Processing Instructions cross-referenced in the policy to identify the appropriate codes for hydrotherapy and wound care services in their specific billing context.
No covered codes are enumerated in NCD 47.
No specific codes are designated as non-covered within the policy data. The non-covered modalities are described by treatment type (ultraviolet light, low intensity direct current, topical oxygen, Balsam of Peru dressings), not by code.
Related ICD-10 Diagnosis Codes: NCD 47 does not list specific ICD-10-CM diagnosis codes. The clinical context of this policy maps to pressure ulcer/pressure injury diagnosis codes; consult your MAC LCD and coding guidelines for the appropriate ICD-10-CM codes for decubitus ulcers at your facility.
What Your Billing Team Should Do
| # | Action Item |
|---|---|
| 1 | Audit current wound care billing protocols by March 1, 2026. Pull a sample of recent Medicare claims for decubitus ulcer treatment and confirm that only hydrotherapy (whirlpool) or other established, covered modalities are being billed. Flag any claims that include ultraviolet light, low intensity direct current, topical oxygen, or Balsam of Peru dressings for immediate review. |
| 2 | Review your MAC's LCD for wound care before the effective date. NCD 47 sets the national floor; your MAC may have a local coverage determination that specifies documentation requirements, covered CPT/HCPCS codes, or frequency limitations that go beyond the NCD. Identify the relevant LCD now and update your billing policies accordingly. |
| 3 | Update clinician documentation templates to capture medical necessity language. Work with your wound care nurses, physicians, and physical therapists to ensure that hydrotherapy orders and treatment notes explicitly address why the treatment is reasonable and necessary for each patient. Generic documentation is a denial risk under the "reasonable and necessary" standard. |
| 4 | Educate front-line staff on non-covered modalities. Ensure that anyone involved in ordering or documenting decubitus ulcer care understands that certain treatment types are excluded from Medicare coverage by name in this NCD. This is particularly important in SNF and long-term care settings where multiple therapy disciplines may be involved in wound care. |
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.