How a Coverage Fix Becomes a Rejection Edit
CMS rescinded and replaced two quarterly NCD change requests on Thursday. One writes a return-as-unprocessable edit into the defibrillator NCD and backdates a place-of-service fix to October 2023, which is two years past the point where you can bill it. The other deletes an eleven-year retroactive payment instruction seven weeks before it was due to install.
Transmittal 13903 was seven days old when CMS pulled it back.
It went out August 7 carrying change request 14570, the January 2027 half of the quarterly NCD coding maintenance. On Thursday CMS rescinded it and issued transmittal 13923 in its place, "to update NCD 20.4 Implantable Cardioverter Defibrillator (ICD) to include additional business requirements for Place of Service (POS) and Claim Adjustment Reason Code (CARC) and Remittance Advice Remark Code (RARC) messages."
The same afternoon it rescinded transmittal 13752, the October 2026 half, and deleted one of that CR's requirements outright.
Two rewrites, one channel, one day. Both still open with "No policy is being changed as a result of these updates."
The fix that arrives with an edit attached
We read the CR 14570 workbook on August 11 and found a line the transmittal did not carry: add place of service 11 to NCD 20.4, effective 10/20/2023. It lived in a spreadsheet inside a zip file and nowhere else.
Transmittal 13923 promotes it. Requirement 14570.4.1 now says it in the CR itself: "Contractors shall add Place of Service (POS) 11 effective October 20, 2023."
Then comes 14570.4.1.1, which is new. Contractors "shall return as unprocessable claims for EVICD services when services were billed in other than Place of Service 11, 19, 21, 22, 24 or 26," using CARC 58, group code CO, and RARC N428.
The rest of this brief is for subscribers.
The impact tables, the code-level detail, and the rest of the analysis sit past this line.
$50 a month, or $500 a year.
Already a subscriber? Sign in