DowncodedHow Much Warning Does an LCD Actually Give You?
CMS sets a 45-day floor on LCD notice and lets any MAC ask for more. Across 448 notice periods since the 2019 process reform, 355 ran exactly 45 days, and only ten cleared 52.
If you have ever tried to talk a MAC into more runway on a coverage change, the answer you got was almost certainly no. CMS's own manual says you can ask.
The rule is one paragraph. Program Integrity Manual chapter 13, section 13.2.6: the day the final LCD posts to the Medicare Coverage Database starts a minimum 45 calendar day notice period, and if the contractor does not extend it, the effective date is the 46th calendar day. The next sentence is the interesting one. "If the MAC would like to extend the notice period, they shall seek approval from CMS BFL."
So the extension exists. We pulled the Medicare Coverage Database's current LCD export, which refreshed Thursday, and counted how often anybody uses it.
448 notice periods have opened on currently active LCDs since the 2019 process reform. Ten of them ran longer than 52 days (chart above).
Four Hundred and Fourteen of Them Are the Floor
Of those 448, 355 ran exactly 45 days. Another 59 ran 46, which is the same window counted with the effective date on the end.
Together that is 92% of every LCD notice period in the post-reform era sitting on the statutory minimum.
The tail is almost empty. One at 47 days, nine at 48, eight at 49, two at 50, one at 51, three at 52.
Then nothing at all until 91. Between 53 and 90 calendar days of notice, across seven and a half years and every jurisdiction, the count is zero.
This year holds the pattern tighter than any before it. 41 notice periods have opened in 2026, 34 of them exactly 45 days, four at 46, three at 48.
Nothing longer than 48 days has posted all year.
Worth knowing if you build calendars: 445 of the 448 opened on a Thursday, because that is the day the MCD publishes. Add 45 and you land on a Sunday, which is where 357 of these effective dates fall.
Your compliance date is a weekend. The first claims that can be wrong are Monday's.
The Ten Times Somebody Got More
Every extension on record since 2019 came in two clusters, and one of them is doing most of the work (chart below).
Two MolDX molecular syndromic panel LCDs, Noridian and CGS, posted March 3, 2022 with 91 days.
Then a burst: eight LCDs at 105 days each, every one of them posted between December 12, 2024 and January 9, 2025. Five MACs, five topics, 29 days apart at the outside.
The topics rhyme:
- Sacroiliac joint arthrodesis, at Palmetto, CGS and Noridian
- Genetic testing in oncology, at Novitas and First Coast
- Urine drug testing, at Noridian
- Magnetic resonance angiography, at Palmetto
- Total shoulder arthroplasty, at Palmetto
Those are high-volume, high-dollar, heavily-contested code families, and they are the only places where a MAC has come away with extra time in seven years.
There is a second read on 105 days that nobody at CMS has published: 45 plus 60. Whatever the requests said, the grants came back in the same size.
What Changed in 2019
The pre-reform corpus behaves differently, which is a useful control. Across the 174 notice periods on active LCDs that opened before 2019, the count that ran exactly 45 days is zero.
The dominant value back then was 46, at 127 of 174. The 2019 rewrite of chapter 13 moved everyone onto the floor and kept them there.
In 2020 the split was 41 at 45 days and 11 at 46. By 2023 it was 60 and zero.
None of that says the MACs are doing anything wrong. Forty-five days is what the manual asks for and forty-five days is what they publish, jurisdiction to jurisdiction, year after year.
The consequence for you is that the number is a constant. Palmetto, Noridian, CGS, WPS, Novitas and First Coast all run a median of 45, and Wellpoint Federal runs 46.
Final Thoughts
CGS posted a revision to its Erythropoiesis Stimulating Agents LCD, L34356, on Thursday. Effective date October 4.
That is 45 days, and the export already carries the date, so the only open question is how fast somebody in your shop reads the policy.
The desk covered one of these in isolation two weeks ago, the Trigger Point Injections revisions at Novitas and First Coast, effective September 6 on a notice period that opened July 23. Also 45 days.
At the time that looked like a fact about two LCDs. It is a fact about all of them.
When a final LCD hits the MCD, the clock is 45 days, it ends on a Sunday, and the odds anybody gets meaningfully more than that are about one in 45. Build the re-coding sprint to fit inside the window and stop waiting on a reprieve that arrives twice a decade.
Thanks for reading.