Physician-Led Utilization Management & Advisory Services
MEDICARE COVERAGE AUTHORITY

Medicare NCD & LCD Coverage Review

National and local coverage determinations are core Medicare coverage authorities. Physician review starts by identifying which policy governs the requested item or service—and whether the submitted record documents the required clinical circumstances.

Coverage hierarchy matters. National policy governs nationally. Local policy applies within the responsible Medicare Administrative Contractor jurisdiction when permitted and applicable.
TWO LEVELS OF MEDICARE COVERAGE POLICY

National when CMS speaks. Local when the MAC has authority.

CMS develops National Coverage Determinations through an evidence-based process. When no controlling national policy resolves the question, Medicare Administrative Contractors may develop Local Coverage Determinations for their jurisdictions, and an LCD may also supplement an NCD so long as it does not conflict with national policy.

NCD

National Coverage Determination

CMS policy addressing whether a particular item or service is covered nationally under Medicare.

  • Authority: Centers for Medicare & Medicaid Services
  • Geography: National
  • Review focus: Covered or noncovered indications, clinical requirements, limitations, and other conditions of coverage
  • Operational effect: National policy is binding within the Medicare coverage system
LCD

Local Coverage Determination

A Medicare Administrative Contractor determination addressing whether an item or service is reasonable and necessary and covered within that MAC's jurisdiction.

  • Authority: Applicable Medicare Administrative Contractor
  • Geography: MAC jurisdiction
  • Review focus: Medical necessity, covered indications, documentation requirements, and related local policy
  • Operational effect: Jurisdiction and current effective policy are essential to the review
MEDICARE COVERAGE HIERARCHY An LCD cannot conflict with a controlling NCD.

When national policy exists, the reviewer applies it first. Local policy may address issues left to contractor discretion or further define requirements within the limits of national Medicare policy.

CMS COVERAGE DOCUMENTSAssociated articles can support an LCD, but an article is not itself an LCD.

Billing and Coding Articles and other MAC articles may provide coding or implementation guidance. Reviewers should confirm whether an article directly supports a specific LCD and verify the current effective document in the Medicare Coverage Database.

HOW PHYSICIAN REVIEW USES NCDs & LCDs

Coverage policy is applied to the actual medical record.

The physician reviewer does not stop after locating a policy. The review must connect the policy requirements to the patient's documented diagnosis, findings, prior treatment, requested service, and other material clinical facts.

1

Identify the service

Define the exact item, procedure, diagnostic study, therapy, or technology being reviewed.

2

Find controlling policy

Determine whether a current NCD applies and, when appropriate, whether a relevant LCD or associated article governs the jurisdiction.

3

Match the record

Assess whether the documentation establishes the required indications, diagnostic findings, prior therapy, eligibility, or other coverage conditions.

4

Make the determination

Integrate the controlling Medicare coverage requirements with the submitted clinical record and clearly explain the reasoning.

ILLUSTRATIVE REVIEW

Specialized diagnostic testing

For a requested Medicare diagnostic service, the physician reviewer first determines whether CMS has established national coverage. If the national policy does not fully resolve the question, the reviewer identifies the applicable MAC jurisdiction and searches for relevant local coverage requirements.

The determination then turns on whether the submitted medical record documents the specific indications, findings, prerequisite testing, or other conditions required by the applicable coverage policy.

CURRENT-SOURCE PRINCIPLE

Coverage policies change. The current source controls the review.

Reviewers should verify the current CMS or MAC policy, effective dates, jurisdiction, associated articles, and applicable revisions rather than relying on a static historical list.

Official CMS Medicare Coverage Database ↗
CMS Medicare Coverage Determination Process ↗CMS Medicare Coverage Database ↗

Need physician review for a Medicare coverage question?

Discuss NCD/LCD applicability, jurisdiction, documentation requirements, medical necessity, appeals, or complex Medicare review needs.

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