Traditional MedicareCoverageHigh impact
Surgical or Other Invasive Procedure Performed on the Wrong Patient
Medicare/CMS - NCD·National Coverage Determination
We identified it
Sep 26, 2026
Summary
This is a National Coverage Determination (NCD 140.8) addressing Medicare coverage policy for surgical or invasive procedures performed on the wrong patient. This policy establishes that Medicare will not cover procedures performed on the wrong patient, treating such events as non-covered services. Billing teams must ensure claims for wrong-patient procedures are identified and denied appropriately to avoid compliance violations.
Action Required
Immediately: Billing team must implement claims screening procedures to identify and deny any claims submitted for surgical or invasive procedures documented as performed on the wrong patient. Ensure all billing staff understand that wrong-patient procedures are non-covered services under Medicare NCD 140.8. Add internal audit controls to flag claims with wrong-patient incident documentation. Communicate policy to all providers and surgical staff that these claims cannot be billed to Medicare and will result in automatic denial. Establish process for identifying and correcting such claims before submission to avoid compliance violations.