HCPCS code C1890 – No implantable or insertable device used

Key takeaways

HCPCS Code C1890 tells Medicare that an ambulatory surgical center (ASC) performed a device-intensive procedure without furnishing the implantable or insertable device.

It is a temporary Level II C-code, effective January 1, 2019, that ASCs report alongside the device-intensive procedure code.

C1890 is payable in the ASC setting only. Hospital outpatient departments must not report it, and the OPPS assigns it status indicator E1.

The operative note must state that no device was furnished, so the C1890 line holds up if the payer asks for records.

Pabau, practice software that holds clinical notes and billing in one patient record, lets coders confirm device status before the claim goes out.

HCPCS Code C1890: Definition and clinical context

HCPCS Code C1890 is the code an ambulatory surgical center (ASC) reports when it performs a device-intensive procedure without an implantable or insertable device. CMS created it as a temporary Level II C-code, effective January 1, 2019, in CMS Transmittal R4204CP.

A device-intensive procedure is one where the device makes up a large share of the cost. Since 2019, CMS has set that line at a device offset above 30 percent of the procedure’s mean cost. Medicare packages the device into the ASC procedure payment, and ASCs do not report packaged codes.

That left Medicare with no way to see when an ASC performed a device-intensive procedure without the device. C1890 is the flag CMS created for that case. The ASC reports it on the same claim as the device-intensive procedure code.

C1890 is an ASC-only code. It is payable in the ASC setting, and hospital outpatient departments must not report it on institutional claims. Under the Outpatient Prospective Payment System (OPPS), it carries status indicator E1.

Official descriptor and payment status

CMS publishes two descriptors for C1890. The long descriptor is No implantable/insertable device used with device-intensive procedures, and the short descriptor is No device w/dev-intensive px.

CMS updates its ASC payment files every quarter. Check the current CMS ASC payment files before you bill a device-intensive procedure.

When to use C1890: Coverage and scope

Report C1890 when all three of these conditions hold for the same claim.

• The claim is an ASC facility claim to Medicare. C1890 is payable in the ASC setting only. It belongs on the ASC’s claim, never on a hospital outpatient claim.
• The procedure code is device-intensive in the ASC setting. CMS identifies device-intensive ASC procedures in its ASC payment files. C1890 only has meaning next to one of those codes.
• No implantable or insertable device was furnished. The procedure went ahead, but the ASC did not furnish the device the procedure normally uses.

CMS states that ASCs must report C1890 in this situation, so it is a required code. Leaving it off makes the claim look like a standard device-intensive case with the device included. The diagram below runs the three checks in order.

What C1890 does not cover

C1890 has a narrow scope. These are the cases where it does not belong.

• Hospital outpatient claims: Hospital outpatient departments must not report C1890 on institutional claims. The OPPS assigns it status indicator E1, so Medicare does not pay it on any outpatient bill type.
• A device was furnished: If the ASC furnished the device, C1890 does not apply. Never report C1890 and a device code for the same procedure, because the two lines contradict each other.
• Procedures that are not device-intensive: CMS defined C1890 for device-intensive procedures only. Next to any other procedure code, it has no basis.
• Devices received free or with credit: A device furnished at no cost or with a manufacturer credit was still furnished. Chapter 14 of the Medicare Claims Processing Manual handles those cases with the FB and FC modifiers.
• The surgeon’s professional claim: C1890 reports the ASC’s facility service. The surgeon’s own claim for the procedure does not carry it.

ASC billing: How to report HCPCS Code C1890

Chapter 14 of the Medicare Claims Processing Manual has ASCs bill Medicare on the ASC X12 837 professional claim format. Form CMS-1500 is used only in rare cases. C1890 goes on that claim, and these steps keep it accurate.

1. Confirm the procedure is device-intensive. Check the procedure code against the device-intensive list in the current ASC payment files before you code.
2. Confirm no device was furnished. Read the operative note. It must state that no implantable or insertable device was used and give the clinical reason.
3. Report the device-intensive procedure code. Use place of service 24, which Chapter 14 assigns to procedures performed in an ASC.
4. Add C1890 on the same claim. CMS requires ASCs to report C1890 along with the device-intensive procedure code it relates to.
5. Check payer rules for non-Medicare claims. CMS created C1890 for Medicare’s ASC payment system. A commercial payer may not recognize it, so confirm before you submit.
6. Keep the operative note retrievable. If the payer asks for records, the note is what supports the no-device line.

C1890 vs. specific HCPCS device codes: Choosing the right code

C1890 reports the absence of a device, while C1769 and C1889 report devices that were used. Coders confuse them because all three sit in the same C-series range.

If a device was used, C1890 is off the table. Look for the most specific device code first, and fall back to C1889 only when none fits. Because ASCs do not report packaged codes, follow your Medicare Administrative Contractor’s instructions on listing device codes.

The AAPC HCPCS code lookup lets coders browse the full C-series descriptor list. Use it to confirm which device code matches the device that was used. Our HCPCS guides for coders walk through other C-series codes in the same format as this page.

Documentation requirements for C1890

C1890 is only as defensible as the documentation that supports it. The operative note must contain three elements before C1890 can be coded compliantly.

• Explicit statement that no device was implanted. A note that simply describes the surgical approach without addressing device placement is insufficient. The surgeon must document, in plain language, that no implantable or insertable device was placed during the encounter.
• Clinical reason for the absence. Payers and auditors will ask why a device-intensive procedure went ahead without the device. The note should record the reason, such as intraoperative findings, patient anatomy, device incompatibility, or a decision to defer placement.
• Date of service linkage. The operative note must correspond to the exact date of service on the claim. If the encounter spanned two calendar dates, document which date the procedure and the no-device determination occurred.

ASCs using claims management software can build a documentation prompt into their pre-claim workflow. A required field confirming device status before a C1890 line is approved stops errors at the source rather than at the payer.

Good medical billing compliance practice also means keeping the full operative record with the claim. Retain it for as long as your payer contracts and state law require.

Medicare and payer coverage policies for HCPCS Code C1890

Medicare recognizes C1890 on ASC claims only. CMS made it payable in the ASC setting and assigned it status indicator E1 under the OPPS, so hospital outpatient claims do not pay it.

The code exists because of how Medicare pays ASCs for device-intensive procedures. That payment method applies when the procedure is furnished with an implanted or inserted device. C1890 is how the ASC reports the cases where no device was furnished.

Commercial payers set their own rules. Before the first claim, check whether each payer recognizes C1890 on ASC claims and what it expects if it does not.

Tracking electronic remittance advice (ERA) on claims that carry C1890 shows how each payer handles the code. A run of rejections from one payer is worth raising with its provider relations team.

Common C1890 reporting errors and how to avoid them

Each error below breaks a rule CMS set for C1890. The table pairs it with the fix.

A structured denial management workflow that tags each rejected C1890 line by cause shows whether the problem is coding, documentation or payer policy. Only a coding or documentation error needs a corrected claim.

Submitting clean claims, with the operative note checked before the claim drops, keeps these errors from reaching the payer at all.

CMS guidance on C1890

For C1890’s reporting rules, go to the document CMS used to create the code: CMS Transmittal R4204CP, section 4.

How Pabau supports C1890 reporting in your ASC

Device status often sits in the operative note while the claim is built in a separate system. A coder then has to cross-check the two by hand. Each missed check risks a C1890 line that is missing, or one that should not be there.

In Pabau, the clinical note and the claim sit in the same patient record. Your billing team can confirm device status in the operative note before a claim is submitted, without switching systems.

The result is fewer corrected claims and a record that answers a payer’s request without a search through separate systems.

Track every claim, every denial, every device flag

Pabau’s claims management tools help ASC billing teams check documentation before claims drop and track denial patterns by payer, so device-coding errors get caught early.

Book a demo

Conclusion

Treat C1890 as a documentation question first and a coding question second. Once the operative note states plainly that no device was furnished, the code follows from the three checks.

Build that check into your review of device-intensive ASC claims. Most of the errors in the table above then get caught before the payer sees them.

The trade-off is one extra review step on every device-intensive claim, which is quicker than reworking a claim after a records request. To see how Pabau helps your billing team check device status before claims go out, book a demo.

Continue your research

Need a structured overview of denial code categories? Denial codes in medical billing covers the CARC and RARC codes that appear most often on ASC facility claims.

Want to understand the full claims cycle before a claim reaches the payer? What is medical billing walks through the end-to-end process from charge capture to payment posting.

Looking for a compliance framework for your billing operations? Medical billing compliance covers the documentation standards, audit risk areas, and payer policy alignment that affect ASC claims.

Frequently asked questions