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LCD coverage variation by Medicare contractor: the same policy, different diagnosis lists

Medicare Administrative Contractors often publish Local Coverage Determinations with the same title, then code them separately. This report compares the covered ICD-10-CM lists of every such title in the MCD release 2026-10-08: 144 of the 168 titles that two or more contractors publish have a coded billing and coding article in at least two versions. Across them, 29,257 of 62,358 title-level covered codes (47%) are covered by some contractors and not others.

Compiled from CMS files by the QuickIntell RCM Editorial Team · Data effective · Method: reference methodology · Report a data correction

Data currency: Medicare Coverage Database LCD export: MCD release October 8, 2026 (effective October 4, 2026); Medicare Coverage Database billing and coding articles: MCD release October 8, 2026 (effective October 4, 2026). Next CMS release: weekly, every Thursday.

Headline numbers

Titles compared
144
of 168 multi-contractor titles
Median share in dispute
7%
covered codes not on every version's list
Titles with most codes in dispute
40
over half of the covered codes
Titles with identical lists
57
Most divergent title
Magnetic Resonance Angiography (MRA)
1,630 codes differ across 3 versions
Contractors compared
7

Titles ranked by divergence

Divergent codes are covered by at least one contractor version of the title and not by all of them. Smallest and largest name the versions with the shortest and longest covered lists; each title links its comparison page with the code-by-contractor matrix.

LCD titles ranked by the number of covered ICD-10-CM codes that only some contractor versions list
Policy titleVersionsCovered (any)DivergentShareSmallest listLargest list
Magnetic Resonance Angiography (MRA)32,0661,63079%L34865 999L34424 1,311
Nerve Conduction Studies and Electromyography72,3151,57368%L35897 1,126L35048 1,938
Scanning Computerized Ophthalmic Diagnostic Imaging (SCODI)62,0821,50272%L34061 720L34380 2,007
Total Joint Arthroplasty32,1021,48971%L33456 1,197L39911 1,670
Erythropoiesis Stimulating Agents41,4891,46999%L34633 326L40334 1,291
Routine Foot Care31,6991,45886%L35138 750L37643 1,041
Speech-Language Pathology31,2911,18392%L33580 169L35070 1,064
Non-Invasive Vascular Studies22,3411,13248%L34045 1,440L33627 2,110
MolDX: Lab-Developed Tests for Inherited Cancer Syndromes in Patients with Cancer41,3511,07880%L39017 273L39040 1,351
Controlled Substance Monitoring and Drugs of Abuse Testing21,33898774%L36393 379L35006 1,310
Vitamin D Assay Testing598389491%L33996 183L34658 882
Psychiatry and Psychology Services21,55885555%L34616 804L33632 1,457
Transthoracic Echocardiography (TTE)21,72384949%L34338 1,168L33577 1,429
Off-label Use of Rituximab and Rituximab Biosimilars284079595%L38920 49L39297 836
Somatosensory Testing486478491%L34433 153L34624 656
Transesophageal Echocardiography (TEE)31,01975374%L34337 464L33579 776
RAST Type Tests21,03469067%L34063 370L33591 1,008
Intraoperative Neurophysiological Testing21,02861760%L34623 615L35003 824
Cosmetic and Reconstructive Surgery570459084%L35090 137L33428 647
Ophthalmology: Posterior Segment Imaging (Extended Ophthalmoscopy and Fundus Photography)21,86154429%L33567 1,480L34399 1,698
Urine Drug Testing586951059%L36668 404L36029 833
Lab: Flow Cytometry21,60745028%L34513 1,245L34215 1,519
Micro-Invasive Glaucoma Surgery (MIGS)749845090%L38223 48L37578 450
Routine Foot Care and Debridement of Nails265342165%L33636 244L34246 641
Removal of Benign Skin Lesions347740284%L35498 134L34200 315

The widest gap is Magnetic Resonance Angiography (MRA): 2,066 codes are covered by at least one of its 3 versions, 436 by all of them. In the five most divergent titles, the ICD-10-CM categories with the most disputed codes are T82 Complications of cardiac and vascular prosthetic devices, implants and grafts (138 codes, Magnetic Resonance Angiography (MRA)); S14 Injury of nerves and spinal cord at neck level (126 codes, Nerve Conduction Studies and Electromyography); S06 Intracranial injury (563 codes, Scanning Computerized Ophthalmic Diagnostic Imaging (SCODI)); S72 Fracture of femur (760 codes, Total Joint Arthroplasty); M05 Rheumatoid arthritis with rheumatoid factor (123 codes, Erythropoiesis Stimulating Agents). The 119 other titles are in the CSV below.

Titles that reach the most states

A title published across most of the country is where a multi-state group meets the most versions of the same rule; the share column shows how much of the covered list is in dispute.

The largest single-contractor outliers

Only here counts codes on this version's covered list that no other version covers; missing counts codes every other version covers that this one does not. A high missing count is where a diagnosis accepted elsewhere is most likely to deny.

Contractor versions that differ most from the other versions of the same LCD title
Policy titleLCDContractorOnly hereMissing
Scanning Computerized Ophthalmic Diagnostic Imaging (SCODI)L34380Wellpoint Federal1,12616
Non-Invasive Vascular StudiesL34045CGS Administrators, LLC231901
Total Joint ArthroplastyL33456Palmetto GBA432700
MolDX: Lab-Developed Tests for Inherited Cancer Syndromes in Patients with CancerL39017CGS Administrators, LLC01,077
Erythropoiesis Stimulating AgentsL34633Wisconsin Physicians Service Insurance Corporation86912
Controlled Substance Monitoring and Drugs of Abuse TestingL36393First Coast Service Options, Inc.28959
Psychiatry and Psychology ServicesL34616Wisconsin Physicians Service Insurance Corporation101754
Speech-Language PathologyL35070Novitas Solutions, Inc.83316
Transthoracic Echocardiography (TTE)L34338CGS Administrators, LLC294555
Routine Foot CareL33941First Coast Service Options, Inc.488339
Magnetic Resonance Angiography (MRA)L34424Palmetto GBA564254
Off-label Use of Rituximab and Rituximab BiosimilarsL39297Wellpoint Federal7914
RAST Type TestsL34063CGS Administrators, LLC26664
Intraoperative Neurophysiological TestingL35003Novitas Solutions, Inc.413204
Ophthalmology: Posterior Segment Imaging (Extended Ophthalmoscopy and Fundus Photography)L34399CGS Administrators, LLC381163

Strictest and most permissive lists, by contractor

For each contractor, the titles it publishes with a coded article where the versions' list sizes differ, how often (and in what share of those titles) its list is the smallest or the largest, how often it is below or above the median of the other versions, and the median of its list size divided by that median.

Per-contractor summary of covered-list size across the LCD titles whose versions differ
ContractorTitlesSmallestLargestBelow othersAbove othersMedian size vs others
CGS Administrators, LLC6631 (47%)21 (32%)36250.99x
Palmetto GBA5014 (28%)12 (24%)15181.00x
Wellpoint Federal4513 (29%)17 (38%)14241.01x
Wisconsin Physicians Service Insurance Corporation418 (20%)19 (46%)12151.00x
Noridian Healthcare Solutions, LLC396 (15%)7 (18%)10111.00x
Novitas Solutions, Inc.288 (29%)6 (21%)17100.96x
First Coast Service Options, Inc.268 (31%)5 (19%)1870.92x

Counting only the titles where the contractor versions' covered lists differ in size, and ranking by share so that contractors publishing more such titles are not favoured, CGS Administrators, LLC has the smallest list in the largest share of its titles: 31 (47%) of the 66 it publishes. Wisconsin Physicians Service Insurance Corporation has the largest list in the largest share: 19 (46%) of the 41 it publishes. Contractors with fewer than 10 such titles are not ranked. These counts describe list size only. A contractor with shorter lists may cover the same conditions through broader instructions, and one with longer lists may add frequency or documentation limits in the policy text; read the LCD before drawing conclusions about how a contractor pays.

Method, limits and reuse

Titles are grouped the way the LCD hub groups them: active LCDs whose normalised titles match or extend one another form a topic, and a topic needs two or more active policies. For each policy, the covered set is every ICD-10-CM code in the covered lists of its linked billing and coding articles (codes are compared undotted, so I65.23 and I6523 are the same code). Versions with no coded article are excluded from that title's comparison. The figures come from the MCD release 2026-10-08 and the FY2027 ICD-10-CM code set and are rebuilt with every weekly export; non-covered lists, frequency limits, modifiers and the policy text are not part of the measure.

Download the per-title CSV. Each topic comparison page lists the versions, the categories where they part and a code-by-contractor sample, with the full matrix as a CSV; the LCD code lookup answers the question for one code, one state and one diagnosis. The reference methodology records file versions and hashes. Figures may be reused with attribution to QuickIntell and a link to this page.

Where QuickIntell fits across jurisdictions

Groups that bill in several MAC jurisdictions meet every version of this policy. QuickAuth coordinates requirement checks and documentation per case with human review, and QuickRCM keeps claim readiness and coverage denials in one workflow.

Frequently asked questions

Do Medicare contractors cover the same diagnoses for the same LCD?

Often not. Of the 144 policy titles where at least two contractors publish a coded billing article, 40 have more than half of their covered ICD-10-CM codes on some contractors' lists and not others, and 57 have identical lists. The median title has 7% of its covered codes in dispute (MCD release 2026-10-08).

Which contractor has the strictest diagnosis lists?

Counting only the titles where the contractor versions' covered lists differ in size, and ranking by share so that contractors publishing more such titles are not favoured, CGS Administrators, LLC has the smallest list in the largest share of its titles: 31 (47%) of the 66 it publishes. Wisconsin Physicians Service Insurance Corporation has the largest list in the largest share: 19 (46%) of the 41 it publishes. Contractors with fewer than 10 such titles are not ranked. A smaller list is not the same as a stricter policy: text, frequency limits and documentation rules also decide coverage.

How is divergence measured?

For each policy title, every contractor version's covered set is the union of the ICD-10-CM codes in the coded billing and coding articles linked to that LCD. Divergent codes are the codes in the union of those sets but not in their intersection: covered by at least one version and not by all. Versions with no coded article are left out and named on the topic page.

Can I reuse the data?

Yes. The CSV has one row per policy title with the counts and the smallest, largest and outlier versions; each topic page offers the full code-by-contractor CSV. The underlying CMS data is public domain; cite QuickIntell and link this page.

Sources

Every figure on this page is taken from the CMS publications below, as released by the Centers for Medicare & Medicaid Services. Projection built 2026-10-10. Verify against the primary file before billing or contracting decisions. The reference methodology explains how each figure is computed from these files.

Disclaimer

Counts are computed from the CMS Medicare Coverage Database export as an operational reference and compare list sizes, not policies. Verify against the current LCD and article on cms.gov before billing. Not legal, clinical or billing advice.

Found a figure that does not match the CMS file? Report a data correction with the CMS file and the value you expected; the request reaches the editorial team through the contact form.