Downcoded

How a Maintenance Update Reopens Three Years of Claims

CMS issued two NCD coding change requests on August 7, both stamped effective January 1, 2027. Not one of the fourteen edits inside them takes effect on that date, one reaches back to October 2023, and the two halves give your MAC different orders on whether to fix the claims it already denied.


On August 7 CMS issued two change requests with the same subject line and one word of difference where it counts.

Transmittal 13906 carries CR 14537, transmittal 13903 carries CR 14570 subtitled "2 of 2." Both are quarterly NCD coding maintenance, both are stamped effective January 1, 2027, and both open with the same sentence: "No policy is being changed as a result of these updates."

Between them they touch twelve national coverage determinations with fourteen dated edits, and none of those edits takes effect on January 1, 2027 (chart below). Ten land on October 1, 2026, one end-dates on September 30, one reaches back to May, one to January 2024, and one to October 20, 2023.

The stamped date is when the instruction becomes operative for the contractor, and the edit dates are dates of service.

So the question is what your MAC owes you on the claims that already went out under the old edit. The two halves answer it differently.

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The impact tables, the code-level detail, and the rest of the analysis sit past this line.

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