CMS WISeR documentation checklist · §6.2.11
Operational Guide v7.0, last updated July 24, 2026 · retrieved 2026-09-14
Cervical Fusion (L39741, L39758, L39793)
CMS: “To meet coverage criteria, the patient’s medical record must contain documentation that fully supports the medical necessity of services. Subsections 6.2.1 to 6.2.13 list the documentation requirements for example services. For detailed documentation requirements, providers who choose to submit a prior authorization request for a WISeR Select Item or Service should refer to the relevant NCDs and/or their MAC jurisdiction’s LCDs and Local Coverage Articles (LCAs), if available, for guidance. They can be found on the Medicare Coverage Database website.”
Select cervical fusion procedure codes are included in CMS’ Prior Authorization Program for Certain Hospital OPD Services.19 WISeR will initially focus on CPT code 22554, which is not included in CMS’ Hospital OPD program. General documentation requirements for cervical fusion for the decompression or stabilization of the cervical spine are as follows:
- For traumatic injuries, including fractures, dislocations, fracture-dislocations, or traumatic ligamentous disruption, documentation of: a) Fractures or dislocations that are likely to result in spinal instability without neurological defects; OR b) Fractures or dislocations associated with neurological defects at the affected level; OR c) Presence of instability
- For spinal tumors involving the spine or spinal canal, documentation of: a) Malignant or benign tumors that have caused instability or neurologic deficit where treatment of the tumor will likely require stabilization of the spine; OR b) Expected treatment of the tumor, whether by chemotherapy or radiation therapy or surgery, will likely cause spinal instability or neurologic deficits; OR c) Presence of instability
- For infection involving the spine in the form of discitis, osteomyelitis, or epidural abscess, documentation of: a) Imaging or other studies (MRI, biopsy, bone aspirate) demonstrating infection AND b) Imaging evidence of vertebral body destruction or documentation that spinal debridement will cause vertebral instability; OR c) Presence of instability
- For deformities that include the cervical spine, documentation of: a) Cervical kyphosis associated with cord compression or atlantoaxial (C1–C2) subluxation or basilar invagination of the odontoid process into the foramen magnum; or subaxial (C2–T1) instability kyphosis, head drop syndrome, post-laminectomy deformity; OR b) Symptomatic pseudarthrosis (non-union of prior fusion) with radiological (e.g., CT or MRI) demonstration of non-union of prior fusion (lack of bridging bone or abnormal motion at fused segment) after 12 months since fusion surgery or with radiographic evidence of hardware failure (fracture or displacement); OR c) Spinal instability after laminectomy; OR d) Rheumatoid arthritis with associated instability; OR e) Cervical degenerative spondylolisthesis with spinal instability (anterolisthesis/posterolisthesis) AND f) Presence of substantial functional limitation, such as severe neck pain or difficulty ambulating or decreased ability to perform Activities of Daily Living or ability to maintain forward gaze OR g) Progression of deformity
- [19] CPT codes 22551 and 22552 for cervical fusion are included in CMS’ Prior Authorization Program for Certain Hospital Outpatient Department Services. For more information, please visit the Prior Authorization for Certain Hospital Outpatient Department Services webpage.