National and Local Coverage Determinations (NCD & LCD) in Medical Billing: The Complete 2025 Guide
Medical billing frequently resembles navigating a complex maze. Each step relies on specific rules, documentation, and codes, and a single misstep can lead to claim denials. Two of the most significant indicators in this complex landscape are NCDs (National Coverage Determinations) and LCDs (Local Coverage Determinations). If you are involved in healthcare, billing, or coding, you have probably encountered these terms and may have pondered: What do they truly signify? How do they influence CPT and ICD coding? What changes are anticipated in reimbursement policies for 2025? Why Should You Be Concerned About NCD and LCD in 2025? These two factors directly determine whether Medicare will reimburse you. Regardless of how impeccable your documentation is or how medically necessary you believe the procedure to be, if it is not included under the appropriate NCD or LCD policy, you are likely to encounter denials. Here’s the important detail: NCDs are applicable nationwide. They are issued by CMS (Centers for Medicare & Medicaid Services). LCDs are specific to regions. They are determined by MACs (Medicare Administrative Contractors) who oversee claims in particular states. Thus, if you are billing in Texas compared to California, the regulations may vary for the same service due to differences in LCDs. What Is an NCD in Medical Billing? An NCD (National Coverage Determination) is a standardized coverage guideline established by CMS. It addresses one essential question: “Is this service covered by Medicare on a national level, and under what circumstances?” For instance: Screening colonoscopies are covered nationwide under certain ICD-10 diagnosis codes associated with preventive screening. TMS (Transcranial Magnetic Stimulation) for depression previously had limited coverage, but the NCD has broadened to encompass specific ICD-10 codes as evidence of its effectiveness has increased. Table: Illustration of an NCD in Action (2025) Service/Procedure Associated CPT Codes Covered ICD-10 Codes 2025 Reimbursement Details Screening Colonoscopy 45378, 45380 Z12.11 (screening for malignant neoplasm of the colon) Completely covered under preventive services, patient cost-sharing is waived. TMS Therapy 90867, 90868 F32.2 (major depressive disorder, severe) Enhanced coverage is anticipated in 2025, accompanied by a slight increase in reimbursement of 3%. And What About LCD in Billing? An LCD (Local Coverage Determination) is where MACs hold authority. It specifies particular conditions, frequency restrictions, and documentation prerequisites for services within its jurisdiction. For example, while the NCD may state “Sleep studies are covered for obstructive sleep apnea,” the LCD in your state could restrict the number of sleep studies allowed annually or necessitate specific documentation of unsuccessful home testing before reimbursement for lab studies. Table: Illustration of an LCD Regulation (2025) Service MAC Region Example CPT Codes LCD Coverage Regulation Polysomnography (sleep study) Noridian (CA, NV) 95810, 95811 Requires documentation of Epworth Sleepiness Scale score and failure of CPAP trial Physical Therapy Palmetto (Southeast) 97110, 97112 Limits sessions to 20 per year unless the physician provides documentation of ongoing progress How Do NCDs and LCDs Influence CPT and ICD Coding? This is where coders must be vigilant. Both NCDs and LCDs connect specific CPT codes (procedures) with ICD-10 codes (diagnoses) to substantiate medical necessity. If you submit a CPT code without a corresponding ICD-10 code included in the NCD/LCD, the claim will be rejected. If you surpass utilization limits set by an LCD, anticipate denials unless appropriate documentation and modifiers are utilized. Example: CPT 93000 (Electrocardiogram, complete) is only eligible for coverage under specific ICD-10 codes such as I20.0 (unstable angina). Billing it with Z00.00 (general health exam) in an area where the LCD does not provide routine coverage will likely result in a denial. What are the updates for NCD and LCD billing in 2025? Here are several key updates to note: 1. Preventive Care Expansion Additionally, ICD-10 codes have been incorporated under NCDs for preventive screenings (colon, breast, lung cancer). Reimbursement rates for preventive services have risen by 2–4% in 2025. 2. Behavioral Health Coverage Growth LCDs across various regions have broadened coverage for tele-mental health consultations using codes 90791, 90834, 90837. Rural areas have been allocated higher reimbursement rates (up to 5% more) to promote accessibility. 3. Chronic Care Management NCDs now acknowledge CPT 99490 (chronic care management) as fully reimbursable with reduced documentation requirements. Payment has increased by 3% in 2025. Quick Tip for Billers and Coders in 2025 Always verify both NCD and LCD policies before submitting claims. Consider NCDs as federal regulations and LCDs as state regulations. Compliance with both is essential for successful reimbursement. How Do You Actually Use NCD and LCD in Daily Billing and Coding? Grasping the concepts of NCD and LCD is one aspect, but the true challenge arises when you are at your desk with patient records, codes, and an impending claim submission deadline. This is where theoretical knowledge is put to the test. Step 1: Always Start with the CPT Code When a provider delivers a service, your coding process commences with identifying the appropriate CPT or HCPCS code. Example: A physician conducts a bone density scan. The CPT code is 77080. The next question is: Will Medicare provide coverage for this service? This is where NCDs and LCDs become relevant. Step 2: Align CPT With ICD-10 Codes Coverage encompasses more than just the procedure; it also involves the rationale behind the necessity of the service. If the bone density scan (77080) is billed alongside M81.0 (age-related osteoporosis without fracture), it is covered under NCD. If billed with Z00.00 (general medical exam), it will be denied due to the absence of a medical necessity connection. Quick Coding Guideline: Medicare and MACs provide lists of ICD-10 codes that are eligible