US · guidance
CMS Pub. 100-04, ch. 36, § 40.12
Billing Procedures Related to Downcoding under the Competitive
Bidding Program
(Rev. 1532, Issued: 06-11-08, Effective: 07-01-08, Implementation: 07-07-08)
The following downcoding guidelines describe situations where Medicare reduces the level of
payment for the prescribed item based on a medical necessity partial denial of coverage for the
additional, not medically necessary, expenses associated with the prescribed item. For
beneficiaries who reside in a CBA and for whom Medicare determines that the prescribed item
should be downcoded to an item that is reasonable and necessary under Medicare’s coverage
requirements, the subsequent scenarios and chart detail the type of supplier that can furnish the
item and the payment for the item.
• Downcodes from a non-bid item to a bid item
In this situation, Medicare payment will be made to any Medicare enrolled supplier on an
assigned or unassigned basis. Medicare payment will be equal to 80 percent of the single
payment amount for the medically necessary bid item.
• Downcodes from a bid item to a non-bid item
Medicare payment in this downcoding scenario will be made to a contract supplier on an
assignment-related basis. Medicare payment will be equal to 80 percent of the lower of
the actual charge or the fee schedule amount for the medically necessary non-bid item.
• Downcodes from a bid item in one product category (category “U”) to a bid item in
another product category (category “S”)
In this case, Medicare payment will be made to a contract supplier for the product
category “U” on an assignment-related basis. Medicare payment would be equal to 80
percent of the single payment amount for the medically necessary bid item in product
category “S”.
Downcoding Scenarios for Beneficiaries Residing in a CBA
From a
Higher
Level of
Service Item
To a
Medically
Necessary
Item
Must be
Furnished by
Assignment
Mandatory
(Y/N)
Medicare Payment Based
Upon
Non-Bid
Item
Bid Item Any
Medicare
Enrolled
Supplier
N Single Payment Amount
for the Medically
Necessary Item
Bid Item Non-Bid
Item
Contract
Supplier
Y Lower of the Actual
Charge or Fee Schedule
Amount for the Medically
Necessary Item
Bid Item in
Product
Category
“U”
Bid Item in
Product
Category
“S”
Contract
Supplier for
Category
“U”
Y Single Payment Amount
for Category “S” for the
Medically Necessary Item
The following scenarios and chart describe situations where the prescribed item for a beneficiary
that does not reside in a CBA, but travels to a CBA is downcoded to an item that is reasonable
and necessary under Medicare’s coverage requirements.
• Downcodes from a non-bid item to a bid item
In this situation, Medicare payment will be made to any Medicare enrolled supplier on an
assigned or unassigned basis. Medicare payment will be equal to 80 percent of the lower
of the actual charge or the fee schedule amount for the medically necessary bid item.
• Downcodes from a bid item to a non-bid item
Medicare payment in this downcoding scenario will only be made to a contract supplier
on an assignment-related basis. Medicare payment will be equal to 80 percent of the
lower of the actual charge or the fee schedule amount for the medically necessary non-bid
item.
• Downcodes from a bid item in one product category (category “U”) to a bid item in
another product category (category “S”)
In this case, Medicare payment will only be made to a contract supplier for the product
category “U” on an assignment-related basis. Medicare payment will be equal to 80
percent of the lower of the actual charge or the fee schedule amount for the medically
necessary bid item in product category “S”.
Downcoding Scenarios for Beneficiaries Who Do Not Reside In a CBA, But Travel to a
CBA
From a
Higher
Level of
Service Item
To a
Medically
Necessary
Item
Must be
Furnished by
Assignment
Mandatory
(Y/N)
Medicare Payment Based
Upon
Non-Bid
Item
Bid Item Any
Medicare
Enrolled
Supplier
N Lower of the Actual
Charge or Fee Schedule
Amount for the Medically
Necessary Item
Bid Item Non-Bid
Item
Contract
Supplier
Y Lower of the Actual
Charge or Fee Schedule
Amount for the Medically
Necessary Item
Bid Item in
Product
Category
“U”
Bid Item in
Product
Category
“S”
Contract
Supplier for
Category
“U”
Y Lower of the Actual
Charge or Fee Schedule
Amount for the Medically
Necessary Item
History
(Rev. 1532, Issued: 06-11-08, Effective: 07-01-08, Implementation: 07-07-08)
Provenance
- Source
- cms.gov
- Retrieved
- 2026-08-25
- Edition
- iom-2026-08-25
- Content hash
8ddc7b678b742c451d2c8317e4c28febd808b488ab1af41ef6eb45a03302c6ac
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