National Coverage Analysis (NCA) Tracking Sheet

Bariatric Surgery for the Treatment of Morbid Obesity - Facility Certification Requirement



The Centers for Medicare and Medicaid Services (CMS) addresses coverage for bariatric surgery in section 100.1 of the Medicare National Coverage Determinations (NCD) Manual. The NCD issued in February of 2006 identified certain bariatric surgery procedures that were covered if certain criteria were met. It also established a requirement that identified bariatric surgery procedures were only covered when furnished at facilities that were certified by the American College of Surgeons (ACS) or by the American Society of Bariatric Surgeons (currently American Society of Metabolic and Bariatric Surgeons (ASMBS)).

CMS has received a formal request from Dr. John Birkmeyer for a reconsideration of the facility certification requirement part of the NCD. Questions have been raised about the facility certification requirement in the NCD and whether facility certification results in improved outcomes of bariatric surgery in Medicare beneficiaries. CMS is opening this national coverage analysis to review the available evidence on this issue.

Benefit Category

Incident to a physician's professional Service
Inpatient Hospital Services
Physicians' Services

Requestor Information

Requestor Name Requestor Letter
J. D. Birkmeyer, MD View Letter

Important Dates

Formal Request Accepted and Review Initiated
Expected NCA Completion Date
Public Comment Period
01/24/2013 - 02/23/2013
Proposed Decision Memo Due Date
Proposed Decision Memo Released
Proposed Decision Memo Public Comment Period
06/27/2013 - 07/27/2013
Decision Memo Released
Comments for this NCA
View Public Comments


Lead Analysts
Deirdre O'Connor
Lead Medical Officers
Lori Paserchia, MD

Medicare Benefit Category Determination Date

Actions Taken

January 24, 2013

CMS initiates this national coverage analysis of the facility certification requirement for coverage of covered bariatric surgery procedures. The initial 30-day public comment period begins with this posting date, and ends after 30 calendar days.

CMS is requesting public comment on the evidence of health benefit outcomes provided by the facility certification requirement for coverage of covered bariatric surgery procedures in the Medicare population.

CMS considers all public comments, and is particularly interested in comments that include clinical studies and other scientific information about the requirement under review and the short and long term outcomes directly related to this requirement.

Instructions on submitting public comments can be found at You can also submit a public comment by clicking on the highlighted word comment in the title bar at the top of this page. We strongly urge that all public comments be submitted through this website. Please do not submit personal health information in public comments. Comments with personal health information may not be posted to the website.

June 27, 2013

September 24, 2013