Incidental Procedures

Policy No: 108
Date of Origin: 12/01/2009
Section: Administrative
Last Reviewed: 04/01/2024
Last Revised: 04/01/2017
Approved: 04/11/2024
Effective: 05/01/2024
Policy applies to: Group and Individual & Medicare Advantage

This policy applies to all physicians, other health care professionals, hospitals and other facilities.


Incidental procedure

A procedure performed at the same time as a more comprehensive procedure. The incidental procedure does not add significant additional work to the physician and/or is integral to the work of the comprehensive procedure.

Separate procedure

The narrative for many Current Procedural Terminology (CPT®) and Healthcare Common Procedure Code System (HCPCS) codes includes a parenthetical statement that the procedure represents a "separate procedure". The inclusion of this statement indicates that the procedure can be performed separately but should not be reported when a related service is performed.

Policy statement

A code determined to be incidental will not be eligible for separate reimbursement and will be denied as included in the allowance for the comprehensive procedure.

National Correct Coding Initiative (NCCI) Policy Manual states that a procedure designated by CPT code descriptor as a "separate procedure" is not separately reportable if performed in a region anatomically related to the other procedure(s) through the same skin incision, orifice, or surgical approach.

Procedures or services considered incidental to a more comprehensive procedure include, but are not limited to, the following:

Codes identified as "separate procedure" are incidental when performed as part of another procedure and will not be separately reimbursed. For example:

CPT code 45330 – Sigmoidoscopy, flexible: diagnostic… (separate procedure)
CPT code 45331 – Sigmoidoscopy, flexible: with biopsy
In this example, CPT code 45330 is incidental to CPT code 45331.

Procedures or services billed using an unlisted code will not be separately reimbursed when considered incidental to a more comprehensive procedure billed on the same date of service. For example:

  • Unlisted code CPT 37799 is billed for implantation of a doppler for CPT code 15756 (Free muscle or myocutaneous flap with microvascular anastomosis). In this example, unlisted CPT code 37799 is considered incidental to a more comprehensive microvascular CPT code 15756.
  • Unlisted CPT codes 17999 or 19499 billed for application of allograft, xenograft, or any other type of related material in the breast (or in other areas of surgery where there is not a specific code provided by CPT); the work of placement of the supportive material is considered as an included component of the primary procedure and not separately reimbursed.
  • Unlisted CPT code 76999 billed for esophageal Doppler hemodynamic management is considered incidental when performed with any anesthesia procedures.


Centers for Medicare & Medicaid Services, General Correct Coding Policies, National Correct Coding Policy Manual for Part B Medicare Carriers (NCCI). Medicare NCCI Policy Manual | CMS Springfield: National Technical Information Service (NTIS).


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