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Endoscopic Submucosal Dissection (ESD)
11.03.18

Policy

MEDICALLY NECESSARY

ESOPHAGEAL SQUAMOUS CELL CARCINOMA AND ESOPHAGEAL DYSPLASIA
Endoscopic submucosal dissection (ESD) of esophageal squamous cell carcinoma and esophageal dysplasia is considered medically necessary and, therefore, covered when ALL of the following criteria are met:
  • The lesion meets ALL of the following criteria:
    • No overt signs of submucosal invasion (e.g., American Joint Committee on Cancer [AJCC] Tis to T1a, Japan Esophageal Society [JES] stages T1a)
    • Well or moderately differentiated
    • Nonulcerated
    • Greater than 1.5 cm
  • There is documentation of low risk of lymph node metastasis (e.g., esophageal ultrasound, histopathological results meet the lesion criteria above)​
EARLY-STAGE ESOPHAGEAL ADENOCARCINOMA AND BARRETT ESOPHAGUS DYSPLASIA
ESD of early-stage esophageal adenocarcinoma and Barrett esophagus dysplasia is considered medically necessary and, therefore, covered when ALL of the following criteria are met:
  • The lesion meets ALL of the following criteria:
    • No overt signs of deep submucosal invasion (e.g., JES stages T1a- to T1b-SM1)
    • Well or moderately differentiated
    • Nonulcerated
    • Greater than 2 cm
  • There is documentation of low risk of lymph node metastasis (e.g., esophageal ultrasound, histopathological results meet the lesion criteria above)
GASTRIC LESIONS SUGGESTIVE OF EARLY ADENOCARCINOMA
ESD of gastric lesions suggestive of early adenocarcinoma is considered medically necessary and, therefore, covered when ALL of the following criteria are met:
  • The lesion meets ALL of the following criteria:
    • No overt signs of deep submucosal invasion (e.g., <500 micron invasion into submucosa)
    • Well or moderately differentiated
    • Intestinal type
    • Ulcerated or nonulcerated
    • Less than 3 cm
  • There is documentation of low risk of lymph node metastasis (e.g., esophageal ultrasound, histopathological results meet the lesion criteria above)​​​
COLORECTAL LESIONS
ESD of colorectal lesions is considered medically necessary and, therefore, covered when ALL of the following criteria are met:
  • The lesion meets ALL of the following criteria:
    • No overt signs of deep submucosal invasion (e.g., Narrow-Band Imaging International Colorectal Endoscopic [NICE] type 1 to 2, Japan NBI Expert Team [JNET] type 1 to 2B, Kudo type I to type Vi)
    • Greater than 2 cm
  • There is documentation of low risk of lymph node metastasis (e.g., histopathological results meet the lesion criteria above)​
NOTE: ESD is considered medically necessary and, therefore, covered if a multidisciplinary team considers ESD the appropriate therapeutic technique to provide a curative resection to a previously noncurative resection of the indications above.

EXPERIMENTAL/INVESTIGATIONAL 

All other uses of ESD are considered experimental/investigational and, therefore, not covered because their safety and/or effectiveness cannot be established by review of the available published peer-reviewed literature.

REQUIRED DOCUMENTATION 
​
​The individual's medical record must reflect the medical necessity for the care provided. These medical records may include, but are not limited to: records from the professional provider's office, hospital, nursing home, home health agencies, therapies, and test reports.

The Company may conduct reviews and audits of services to our members, regardless of the participation status of the provider. All documentation is to be available to the Company upon request. Failure to produce the requested information may result in a denial for the service.

Guidelines

EXPERTISE GUIDELINES

Endoscopic submucosal dissection (ESD) is a highly technical procedure that requires expertise for a safe and effective procedure. The American Society for Gastrointestinal Endoscopy Training Committee (2021) published a general overview of training practices. It identifies that potential ESD trainees should complete at least 1000 upper gastrointestinal endoscopies or 500 colonoscopies before considering performing ESD training. Additionally, the trainee should understand the different assessments of lesions, with different methods (e.g., Paris classification, Kudo’s pit pattern classification, Narrow-Band Imaging International Colorectal Endoscopic [NICE] classification). The European Society of Gastrointestinal Endoscopy (2019) outlines skills, training, and competency requirements for ESD trainees.

TUMOR INVASION CLASSIFICATIONS
​
There are several different cancer staging classifications, which can make communication of diagnoses difficult, particularly across different nations. Below are several tumor invasion staging classifications that are commonly referenced in clinical guidelines relevant to ESD. Tumor invasion is a critical piece of information necessary to determine the appropriate use of ESD.

ESOPHAGEAL SQUAMOUS CELL CARCINOMA AND ESOPHAGEAL DYSPLASIA TUMOR INVASION STAGING​

American Joint Committee on Cancer (AJCC) (8th edition, Clinical Staging)​Japan Esophageal Society's Japanese Classification of Esophageal Cancer (JES) (12th edition)
Tis – High-grade dysplasia, defined as malignant cells confined by the basement membrane
T1a-EP (M1) – Carcinoma in situ (Tis)
T1a – Tumor invades the lamina propria or muscularis mucosaeT1a-LMP (M2) – Tumor invades lamina propria mucosae
*T1b – Tumor invades the submucosaT1a-MM (M3) – Tumor invades muscularis mucosae
 *T1b-SM1 (SM1) – Tumor invades the upper third of the submucosal layer
 *T1b-SM2 (SM2) – Tumor invades the middle third of the submucosal layer
 *T1b-SM3 (SM3) – Tumor invades the lower third of the submucosal layer

*Indicates invasion to submucosa.

 

​EARLY STAGE ADENOCARCINOMA AND BARRETT ESOPHAGUS DYSPLASIA TUMOR INVASION STAGING

American Joint Committee on Cancer (AJCC) (8th edition, Clinical Staging)Japan Esophageal Society's Japanese Classification of Esophageal Cancer (JES) (12th edition)Japanese Classification of Gastric Carcinoma (JCJC) (15th edition)
Tis – High-grade dysplasia, defined as malignant cells confined by the basement membraneT1a-EP (M1) – Carcinoma in situ (Tis)Tis – Carcinoma in situ. Intraepithelial tumor without invasion of the lamina propria
T1a – Tumor invades the lamina propria or muscularis mucosaeT1a-LMP (M2) – Tumor invades lamina propria mucosaeT1a – Tumor invades lamina propria or muscularis mucosae
*T1b – Tumor invades the submucosaT1a-MM (M3) – Tumor invades muscularis mucosae*T1b – Tumor invades submucosa
 *T1b-SM1 (SM1) – Tumor invades the upper third of the submucosal layer 
 *T1b-SM2 (SM2) – Tumor invades the middle third of the submucosal layer 
 *T1b-SM3 (SM3) – Tumor invades the lower third of the submucosal layer 

*Indicates invasion to submucosa.

 

​GASTRIC LESION SUGGESTIVE OF EARLY ADENOCARCINOMA TUMOR INVASION STAGING

American Joint Committee on Cancer (AJCC) (8th edition, Clinical Staging)Japanese Classification of Gastric Carcinoma (JCJC) (15th edition)
Tis – Carcinoma in situ. Intraepithelial tumor without invasion of the lamina propria, high grade dysplasiaTis – Carcinoma in situ. Intraepithelial tumor without invasion of the lamina propria
T1a – Tumor invades lamina propria or muscularis mucosaeT1a – Tumor invades lamina propria or muscularis mucosae
*T1b – Tumor invades submucosa*T1b – Tumor invades submucosa

*Indicates invasion to submucosa.

 

​COLORECTAL LESIONS TUMOR INVASION STAGING  ​

American Joint Committee on Cancer (AJCC) (8th edition, Clinical Staging)NBI International Colorectal Endoscopic (NICE)Japan NBI Expert Team (JNET)Haggitt et al. 1985Kudo et al. 1996Kikuchi et al. 1995
Tis – Carcinoma in situ, intramucosal carcinoma (involvement of lamina propria with no extension through muscularis mucosae) Type 1 – dark or white spots of uniform size, or homogenous absence of pattern; most likely hyperplastic/sessile serrated polypType 1 – regular dark or white spots, similar to surrounding normal mucosa; most likely hyperplastic polyp/sessile serrated polypLevel 0 – invasion limited to the mucosa without invasion of submucosaType I – round (normal) pits; most likely normal pathology1 – depth of invasion into the first third of the submucosa
*T1 – Tumor invades the submucosa (through the muscularis mucosa but not into the muscularis propria)

*Type 2 – oval, lobular, or branched white structures surrounded by brown vessels; most likely adenoma.

Consists of Vienna classification type 3, 4, and superficial 5 (all adenoma with either low- or high-grade dysplasia, or with superficial submucosa carcinoma)

Type 2A – regular (tubular/branched/papillary); most likely low-grade intramucosal neoplasiaLevel 1 – invasion of submucosa, but limited to the head of the polypType II – asteroid pits; most likely hyperplastic polyp or sessile serrated lesion2 – depth of invasion into the middle third of the submucosa
  *Type 2B – irregular or obscure; most likely high grade intramucosal neoplasia/superficial submucosal invasive cancerLevel 2 – invasion extending into the neck of the polypType IIIS – tubular or round pits, smaller than the normal pits; most likely adenoma or intramucosal carcinoma3 – depth of invasion into the deepest third of the submucosa
   Level 3 – invasion extending into any part of the stalkType IIIL – Tubular or round pits, larger than normal pits; most likely adenoma 
   *Level 4 – invasion beyond the stalk but above the muscularis propriaType IV – branched or gyrus-like pits; most likely adenoma or intramucosal carcinoma 
   
 *Type Vi – irregular arrangement and sizes of type IIIS, IIIL, IV pit patterns; most likely intramucosal cancer or superficial submucosal cancer 

*Indicates invasion to submucosa.


​BENEFIT APPLICATION 

Subject to the terms and conditions of the applicable benefit contract, ESD is covered under the medical benefits of the Company’s products when the medical necessity criteria listed in this medical policy are met.​

Description

BACKGROUND

There are two endoscopic resection procedures commonly used for diagnostic and potentially therapeutic purposes for pre-cancer and early cancers of the digestive tract: endoscopic mucosal resection (EMR) and endoscopic submucosal dissection (ESD). Although EMR has historically been the primary minimally invasive technique, ESD provides potential solutions to the limitations of EMR. Primarily, ESD can be used for larger lesions. Because EMR is limited by the size of snare, larger lesions are unable to be removed in one piece, both superficially and deep. This makes it difficult for an accurate pathohistological assessment, which can lead to cancer remaining in the body, cancer recurrence, and unnecessary surveillance/treatment.


ESD allows for the removal of larger lesions because of the use of dissecting knives (rather than a snare) and deeper removal of tissue (submucosa rather than mucosa). However, ESD is not without limitations. First, this technique requires a significant level of expertise, particularly in parts of the digestive tract that have thinner tissue layers. Second, the expertise is required due to the inherent risk of bleeding, perforation, and stricture (primarily seen with ESD in the esophagus), among other challenges associated with endoscopic procedures. Third, ESD has longer procedure times compared to EMR. Fourth, as with EMR, there is a risk associated with improper triage to ESD, where surgery and/or lymph node dissection would have been more appropriate. Nevertheless, ESD provides an endoscopic resection technique for larger lesions that can be both diagnostic and therapeutic.


PROFESSIONAL SOCIETY GUIDELINES


ENDOSCOPIC SUBMUCOSAL DISSECTION OF ESOPHAGEAL SQUAMOUS CELL CARCINOMA AND ESOPHAGEAL DYSPLASIA

The National Comprehensive Cancer Network (NCCN) Esophageal and Esophagogastric Junction Cancers guideline (2026) describes the dual utility of endoscopic resection (both ESD and EMR) for diagnostic and therapeutic purposes. The guideline does not provide explicit preference for one technique over the other for diagnostic purposes. However, after a diagnostic endoscopy and biopsies have concluded that early stage esophageal squamous neoplasia does not contain high-risk features (i.e., nonulcerated, not poorly differentiated, no lymphatic invasion), a preference for EMR or ESD is based on size. If the lesion is 15 mm or greater, ESD is preferred. If the lesion is less than 15 mm, then ESD or EMR can be used (although ESD may be preferred if the lesion is >10 mm or the morphology is suspicious for deep submucosal invasion).


​​In 2023, the American Society for Gastrointestinal Endoscopy (ASGE) published a summary of recommendations (low quality of evidence) for ESD for the management of early esophageal and gastric cancers, as follows: 

  • Esophageal squamous dysplasia or early-stage esophageal squamous cell carcinoma (ESCC); well differentiated, nonulcerated; without submucosal invasion; measuring greater than 15 mm: ESD over EMR is suggested.
  • Esophageal squamous dysplasia or early-stage ESCC; well differentiated, nonulcerated; without submucosal invasion; measuring 15 mm or less: no recommendation is made for or against either ESD or EMR.

In 2023, the Japan Esophageal Society (JES) published an esophageal cancer practice guideline with the following recommendations (no differentiation between squamous cell carcinoma [SCC] and adenocarcinoma):

  • T1a-EP/LPM/MM non-circumferential: EMR or ESD
  • T1a-EP/LPM whole-circumferential, 5 cm or less: ESD

In 2022, the European Society of Gastrointestinal Endoscopy (ESGE) published a guideline for ESD of superficial gastrointestinal lesions, with the following ESCC recommendations:

  • ESGE recommends ESD as the treatment of choice for most esophageal squamous cell and gastric (or junctional non-Barrett) superficial lesions, mainly to provide en bloc potentially curative resection with accurate pathological staging. Strong recommendation, moderate quality of evidence.
  • ESGE suggests that ESD might also be considered for en bloc resection of noncircumferential clinically staged T1a-m3/T1b-sm1 or for circumferential clinically staged T1a-m1/m2 esophageal SCC. Weak recommendation, moderate-quality evidence.

In 2020, the Korean Society of Gastrointestinal Endoscopy (KSGE) published a clinical practice guideline for endoscopic resection of early gastrointestinal cancer, recommending that:

  • ESD rather than EMR for en bloc and curative resection of ESCC confined to the mucosa (grade of recommendation, strong; level of evidence, moderate). Additionally recommended is consideration of ESD first, regardless of the lesion size because ESD has higher en bloc and curative resection rates than EMR for ESCC confined to the mucosa, and has complication risks within an acceptable range. If the operator lacks experience with ESD, then EMR could be considered for only lesions smaller than 10 mm.

ENDOSCOPIC SUBMUCOSAL DISSECTION OF EARLY STAGE ESOPHAGEAL ADENOCARCINOMA AND BARRETT ESOPHAGUS DYSPLASIA​

The NCCN's Esophageal and Esophagogastric Junction Cancers guideline (2026) describes the dual utility of endoscopic resection (both ESD and EMR) for diagnostic and therapeutic purposes. The guideline does not provide explicit preference for one technique over the other for diagnostic purposes. However, after a diagnostic endoscopy and biopsies have concluded that early-stage esophageal high-grade dysplasia (HGD)/adenocarcinoma has a visible lesion present and does not contain high-risk features (i.e., nonulcerated, not poorly differentiated, no lymphatic invasion), a preference for EMR or ESD is based on size. If the lesion is 2 cm or greater, ESD is preferred. If the lesion is less than 2 cm, ESD or EMR can be used (although ESD may be preferred if the morphology is suspicious for deep submucosal invasion). If there is either high-grade dysplasia or early carcinoma, there is no preference for ESD or EMR.


In 2024, the American Gastroenterological Association (AGA) published a clinical practice guideline on endoscopic eradication therapy (EET) of Barrett esophagus and related neoplasm. The guideline suggests the use of EMR or ESD for individuals with Barrett esophagus with neoplastic lesions undergoing endoscopic resection. The guideline suggests the following implementation considerations:

  • Individuals suspected of having T1 esophageal adenocarcinoma (EAC) should be referred for consideration of EET.
  • Endoscopic resection is the test of choice over endoscopic ultrasound for distinguishing EAC from HGD and for staging depth of invasion in early cancer.
  • The vast majority of neoplastic lesions may be managed with EMR rather than ESD.
  • Individuals with large bulky neoplastic lesions or lesions highly suspicious of at least T1b invasion (e.g., those with depressed, Paris IIc or IIa+c lesions) and deemed candidates for endoscopic resection might benefit from ESD over EMR.
  • Individuals with previously failed EMR might benefit from ESD.

As mentioned previously, ASGE published a summary of recommendations for ESD for the management of early esophageal and gastric cancers. ASGE provides the following conditional, low quality of evidence recommendations:

  • Early-stage EAC (T1) or Barrett nodular dysplasia; well differentiated, nonulcerated; measuring over 20 mm: ESD over EMR is suggested. 
  • Early-stage EAC (T1) or Barrett nodular dysplasia; well differentiated, nonulcerated; measuring 20 mm or less: no recommendation is made for or against ESD or EMR.​​

JES published an esophageal cancer practice guideline in 2023. They provided the following recommendations (not differentiated between SCC and adenocarcinoma):

  • T1a-EP/LPM/MM non-circumferential: either EMR or ESD 
  • T1a-EP/LPM whole-circumferential, 5 cm or less​: ESD​

ESGE published a guideline for ESD of superficial gastrointestinal lesions. They provided the following recommendations for Barrett esophagus–associated lesions:

  • ESGE recommends using EMR for visible lesions 20 mm or less with low probability of submucosal invasion (Paris type 0-IIa, 0-IIb) and for larger or multifocal benign (dysplastic) lesions. Strong recommendation, high-quality evidence.
  • For Barrett esophagus–associated lesions, ESGE suggests using ESD for lesions suspicious for submucosal invasion (Paris type 0-Is, 0-IIc), for malignant lesions larger than 20 mm, and for lesions in scarred/fibrotic areas. Weak recommendation, low-quality evidence.

In 2020, the Japan Gastroenterological Endoscopy Society (JGES) published a guideline outlining endoscopic ESD and EMR for esophageal cancer. JGES provides the following explicit recommendation of ESD over EMR. ESD was strongly recommended over EMR for the radical treatment of superficial EAC suitable for endoscopic resection.

 

ENDOSCOPIC SUBMUCOSAL DISSECTION OF GASTRIC LESIONS SUGGESTIVE OF EARLY ADENOCARCINOMA

The NCCN's Gastric Cancer guideline (2026) describes the dual utility of endoscopic resection (both ESD and EMR) for diagnostic and therapeutic purposes. The guideline does not provide explicit preference for one technique over the other for diagnostic purposes. However, after the appropriate diagnostic workup, an early-stage gastric adenocarcinoma with a favorable pathology (i.e., well- or moderately differentiated, intestinal-type) and not suggestive of deep submucosal invasion, ESD is the preferred endoscopic technique, for lesions 2 cm or less.


​ASGE published a summary of recommendations for ESD for the management of early esophageal and gastric cancers. ASGE provided the following conditional, low quality of evidence recommendations:

  • Well- or moderately differentiated early-stage gastric adenocarcinoma; nonulcerated, intestinal type; measuring 20–30 mm: ESD over EMR is suggested. 
  • Well- or moderately differentiated early-stage gastric adenocarcinoma; nonulcerated, intestinal type; measuring less than 20 mm; no recommendation for or against ESD or EMR is made. ​

ESGE published a guideline for ESD of superficial gastrointestinal lesions. ESGE provided the following gastric lesion recommendations:

  • ESD for differentiated gastric lesions clinically staged as dysplastic or as intramucosal carcinomas (of any size if not ulcerated and ≤ 30 mm if ulcerated), with EMR being an alternative for Paris 0-IIa lesions of size 10 mm or less with low likelihood of malignancy. Strong recommendation, moderate-quality evidence.
  • Gastric adenocarcinomas that are 30 mm or less, submucosal (sm1), and well-differentiated, or 20 mm or less, intramucosal, and poorly differentiated type, both without ulcerative findings, can be considered for ESD, although the decision should be individualized. Weak recommendation, low-quality evidence.

In 2021, the JGES, in collaboration with the Japanese Gastric Cancer Association (JGCA), published a guideline outlining ESD and EMR for early gastric cancer. They provide the following absolute indications for ESD, with a strong recommendation, based on moderate evidence:

  • Nonulcerated, clinically intramucosal (cT1a), differentiated-type carcinomas with a long diameter greater than 2 cm
  • Ulcerated, cT1a, differentiated-type carcinomas with a long diameter of 3 cm or less
  • Non-ulcerated, cT1a, nondifferentiated-type carcinomas with a long diameter of 2 cm or less ​

ENDOSCOPIC SUBMUCOSAL DISSECTION OF COLORECTAL LESIONS

In 2024, ESGE published a colorectal polypectomy and EMR guideline update. ESGE provides the following recommendations:

  • ESD may also be suggested as an alternative for removal of large nonpedunculated adenomatous polyps of sized 20  mm or greater in selected cases and in high-volume centers. Weak recommendation, low quality of evidence.
  • En bloc resection techniques, such as en bloc EMR, ESD, endoscopic intermuscular dissection, endoscopic full-thickness resection (EFTR), or surgery should be the techniques of choice in cases with suspected superficial invasive carcinoma, which otherwise cannot be removed en bloc by standard polypectomy or EMR. Strong recommendation, moderate quality of evidence.

​ESGE published a guideline for ESD of superficial gastrointestinal lesions. ESGE provided the following colorectal lesion recommendations:
  • ESGE recommends polypectomy and/or EMR (en bloc or piecemeal) as the treatment of choice for most superficial colorectal lesions. Strong recommendation, high-quality evidence.
  • ESGE suggests that ESD should be considered for en bloc resection of colorectal (but particularly rectal) lesions with suspicion of limited submucosal invasion (demarcated depressed area with irregular surface pattern or a large protruding or bulky component, particularly if the lesions are >20 mm), or for lesions that otherwise cannot be completely removed by snare-based techniques. Weak recommendation, moderate-quality evidence.

In 2022, the American Society of Colon and Rectal Surgeons (ASCRS) published clinical practice guidelines for the management of colon cancer. ASCRS provided the following recommendations:

  • For individuals with a "malignant polyp," either endoscopic excision or oncological resection may be appropriate depending largely on polyp histopathological features and completeness of excision. Grade of recommendation: strong recommendation based on moderate-quality evidence, 1B.
  • A low-risk malignant pedunculated or sessile polyp may be defined as one with well- or moderately differentiated cancer, no lymphovascular invasion or perineural invasion, no or low tumor budding, a negative resection margin, and less than 1 mm submucosal invasion depth. Endoscopic excision is generally considered definitive treatment for these malignant polyps as the risk of residual disease in the colon wall or cancerous lymph nodes is negligible.

KSGE published a clinical practice guideline for endoscopic resection of early gastrointestinal cancer. KSGE provided the following recommendation:

  • En bloc and histologically complete resection should be achieved for endoscopic treatment of a suspected or established early colorectal cancer. They recommended ESD for the treatment of endoscopically resectable early colorectal cancer that cannot be resected en bloc using EMR technique (grade of recommendation, strong; level of evidence, moderate).

In 2020, the US Multi-Society Task Force on Colorectal Cancer, which comprises the American College of Gastroenterology, the American Gastroenterological Association, and ASGE, published a recommendation guideline on endoscopic removal of colorectal lesions. The Task Force provided the following recommendation:

  • The indications for colorectal ESD are relatively few, even at experienced centers, because most colorectal neoplasms are benign and can be resected using piecemeal EMR with minimal risk of recurrence. Large-sized (>20 mm in diameter) lesions that are indicated for endoscopic rather than surgical resection, and in which en bloc resection using inject-and-cut EMR is difficult, may be considered. These include lesions suspected to have submucosal invasion (i.e., large, depressed lesion or pseudodepressed LST-NG lesion), mucosal lesions with fibrosis, local residual early carcinoma after endoscopic resection, and nonpolypoid colorectal dysplasia in individuals with inflammatory bowel disease.

PEER-REVIEWED LITERATURE


ENDOSCOPIC SUBMUCOSAL DISSECTION OF ESOPHAGEAL SQUAMOUS CELL CARCINOMA AND ESOPHAGEAL DYSPLASIA

In 2022, Liu and Zhao conducted a systematic review and meta-analysis comparing ESD to esophagectomy (ESO) as treatment options for superficial squamous esophageal cancer. Studies of all designs were included, so long as they compared hospital stay duration, procedure duration, recurrence, complications, or survival (primary outcome). Sixteen studies were included in the analysis, comprising 13,262 individuals (ESD, N=5213; ESO, N=8049). Hospital stay and procedure duration were both significantly decreased for individuals who received ESD, while there was no difference in recurrence. Complications and all-cause mortality were both significantly decreased for individuals who received ESD, while short-term (<3 years) and long-term (>3 years) were not significantly different. Because there was no mention of staging, it is unclear whether these procedures were indicated for similar individuals. Additionally, the review is limited by the included study types and heterogeneous outcomes of the studies.


In 2020, Wang et al. conducted a meta-analysis comparing ESD to EMR. Only studies that compared these two procedures were included in the review. In eight of the nine studies, the average lesion size treated with ESD was larger than those treated with EMR. ESD had a significantly greater en bloc resection rate and complete resection rate, although both have high heterogeneity. Local recurrence rate was significantly lower in the ESD group, but there were significantly more complications. ESD procedure time was also significantly greater.


Yeh et al. (2020) investigated the long-term outcomes of ESD compared to surgery for superficial esophageal SCC via a systemic review and meta-analysis. Varying study designs were included. The primary outcomes were overall survival, disease-specific survival, and recurrence-free survival. Of the studies that compared ESD and ESO, 638 lesions were treated with ESD and 546 lesions were treated with ESO. There was nearly a significant difference in depth of invasion between the groups (P=0.057), but there was no difference in lesion size. Five-year overall survival, disease-specific survival, and recurrence-free survival were not significantly different.


The NCCN Esophageal and Esophagogastric Junction Cancers guideline recommends ESD or EMR for lesions less than 15 mm with no high-risk features (i.e., muscularis mucosa or submucosal invasion, poorly differentiated, and lymphovascular invasion). The guideline then clarifies that “ESD may be preferred for lesions >10 mm in size; morphology suspicious for deep submucosal invasion should be specifically considered for ESD." The tentative language in the clarification (i.e., “may be preferred") is worth noting. Further, while the clarification preferentially suggests ESD for the treatment lesions “suspicious of deep submucosal invasion," this is a contraindication for ESD altogether. This is in fact a high-risk feature, for which NCCN recommends neither ESD nor EMR. Beyond 15 mm, with no high-risk features, ESD is preferred. Thus, this 10- to 15-mm lesion size range is under question, of which there are insufficient data to support ESD over EMR, given (1) the increased complexity and associated risks of ESD, and (2) EMR is already established as the technique for this lesion size.


ENDOSCOPIC SUBMUCOSAL DISSECTION OF EARLY-STAGE ESOPHAGEAL ADENOCARCINOMA AND BARRETT ESOPHAGUS DYSPLASIA

In 2024, Radadiya et al. conducted a systematic review and meta-analysis comparing ESD and EMR for Barrett-associated neoplasia. Twenty-three studies on ESD, 19 studies on EMR, and five comparative studies were included in the review. The average size of lesions treated with ESD were 22.5 mm and those with EMR were 15.8 mm. The en bloc, R0, and curative resection rates for ESD and EMR are as follows: 98%, 78%, 65%, and 37%, 67%, 62%. The mean procedure times were 113 minutes for ESD and 22 minutes for EMR.


Doumbe-Mandengue et al. (2022) conducted a systematic review of ESD for early esophagogastric junction adenocarcinomas. Studies included EAC​ and gastric cardia adenocarcinoma (GCA). For both adenocarcinoma locations, lesion size was between 15 and 20 mm, with the size of resection twice as large. En bloc resection was greater than 95% in 12 of 17 studies investigating EAC, and four of six studies investigating GCA. R0 resection rate was lower in EAC studies compared to GCA studies. Recurrence rate was between 0% and 19% in EAC and 0% and 2.4% in GCA, although the duration of follow-up was variable.


Han and Sun (2021) conducted a systematic review and meta-analysis of ESD compared to EMR of various histological types of esophageal cancers. In total, nine studies enrolled individuals with squamous cell carcinoma, eight studies involved individuals with Barrett esophagus with associated neoplasia and/or EAC, three reports included multiple histological types, and two studies only stated enrolling individuals with superficial esophageal carcinoma without specifying the histological types. Of the studies that investigated Barrett esophagus or EAC, ESD lesions were larger in all but one study. ESD lesions ranged between 10 and 40 mm, while EMR lesions ranged between 5.5 and 30 mm. Overall, including all histologic types, ESD had a higher en bloc resection rate compared with EMR. Again, across all subtypes, a subgroup analysis revealed higher en bloc and curative resection rates among lesions treated with ESD for lesions 11 mm or greater (statistically significant, although very wide confidence intervals). The authors conclude that ESD is considered the best endoscopic procedure for lesions greater than 20 mm, while EMR and ESD can both be considered for lesions between 11 and 20 mm (regardless of histological type).


Again, as with esophageal squamous cell carcinoma and esophageal dysplasia, the NCCN Esophageal and Esophagogastric Junction Cancers guideline concerning adenocarcinoma requires consideration. The guideline recommends either ESD or EMR for lesions less than 2 cm with no high-risk features (e.g., deep submucosal invasion, poorly differentiated, and lymphovascular invasion). Yet, the guideline clarifies that “Morphology suspicious for deep submucosal invasion should be specifically considered for ESD." Again, this is contradictory to the prior statement. Thus, lesions less than 2 cm are under question, of which there are insufficient data to support ESD over EMR, given (1) the increased complexity and associated risks of ESD, and (2) EMR is already established as technique for this lesion size.


ENDOSCOPIC SUBMUCOSAL DISSECTION OF GASTRIC LESIONS SUGGESTIVE OF EARLY ADENOCARCINOMA

Benites-Goñi et al. (2023) conducted a systematic review and meta-analysis of short-term outcomes of ESD for the treatment of superficial gastric neoplasms in non-Asian countries. The vast majority (80.9%) of lesions were located exclusively to the mucosa. En bloc resection was reported in 26 of 27 studies (all 27 were either case-series and cohorts), which was achieved in 96% of resections. All studies reported R0 resection rate, which was achieved in 85% of resections. Twenty-four studies reported curative resection rates, which was achieved in 77% of resections. The overall bleeding and perforation rates were 5% and 2%, respectively.


In 2023, Agrawal et al. conducted a systematic review of ESD in gastric tube cancers following esophagectomy. A total of 192 ESDs were performed across seven retrospective studies. The tumor size ranged between 15 mm and 26 mm. The en bloc resection rate was 92.5% when all seven studies were combined, while complete resection rate was 78.9% as reported in only three studies. Curative resection was reported in four studies, with a combined 73.9%. Three studies reported intraprocedural complication rate (10.2%) and all seven studies reported postprocedure complication rates (11.1%). Five-year survival was reported in three studies (65.5%).


In 2022, Yang et al. compared the long-term outcomes of ESD and surgery for undifferentiated-type gastric cancer via a systematic review and meta-analysis. The study reported outcomes in aggregate and propensity-score matched. Overall survival was greater in the ESD aggregate compared with surgery, but when propensity score matched, there was no difference. Disease-free survival was significantly lower in the ESD and propensity-score matched analysis. Disease-specific survival was not significantly different, regardless of analysis type.


Zhao et al. (2022) conducted a systematic review and meta-analysis of ESD for early gastric cancer in elderly and nonelderly individuals. Tumor size ranged between 12.2 mm and 23.5 mm. “Elderly" was defined differently in the various individual studies, but overall, there was no difference in en bloc resection rate between the two groups (elderly, N=2364; nonelderly, N=3782). This is also true for each subgroup analysis (i.e., >65 vs. <65, >75 vs. <75, >80 vs. <80). Complete histological resection was also not significantly different between the groups. Adverse events and length of hospital stay were also not significantly different, except for pneumonia. Pneumonia was significantly greater in the elderly populations.


Huh et al. (2021) conducted a systematic review and meta-analysis of ESD compared to surgery for the treatment of undifferentiated-type early gastric cancer. Complete resection rate was significantly greater in the surgery group, while the adverse events proportion and overall survival were similar. Recurrence of disease significantly favored surgery compared to ESD.


ENDOSCOPIC SUBMUCOSAL DISSECTION OF COLORECTAL LESIONS

In 2024, Malik et al. conducted a systematic review and meta-analysis of ESD for colorectal dysplasia in individuals with inflammatory bowel disease. Twelve studies were included in the review, consisting of 291 lesions. The average lesion size ranged between 19 mm and 40.7 mm. En bloc, R0, and curative resections were achieved in 92.5%, 81.5%, and 48.9% of resections, respectively. Thirteen percent of individuals required additional surgery following ESD. Bleeding and perforation occurred in 7.7% and 5.3% of individuals, respectively.


Singh et al. (2023) conducted a systematic review and meta-analysis of colorectal ESD, focused on Western countries. Thirty-three studies were included in the review, totaling 4206 individuals. Lesions were summarized by Paris classification and histopathology. The average lesion size ranged between 2.3 cm and 6.8 cm. En bloc, R0, and curative resections were achieved in 84.6%, 75.6%, and 81.9% of lesions, respectively. Bleeding and perforation occurred in 4.1% and 5.5% of individuals, respectively. Five percent of individuals required additional surgery following ESD. A subgroup analysis revealed that high-volume centers (>40 procedures annually) performed better than low-volume centers, although only en bloc resection rate was significantly different.


Wang et al. (2023) conducted a systematic review and meta-analysis comparing ESD and EMR of colorectal adenoma and tumors. Twelve studies were included in the review. Lesions treated with EMR were an average 11 mm smaller than those treated with ESD and EMR operating time was 53 minutes shorter than ESD. The odds of an en bloc and R0 resection both favored ESD over EMR. Complications were higher among individuals treated with ESD, but recurrence was lower.


In 2022, Nishizawa et al. conducted a systematic review of long-term outcomes of ESD for colorectal epithelial neoplasms. Notably, studies that required additional surgery after ESD were excluded, which may bias both long- and short-term outcomes. Regardless, en bloc and curative resections were obtained 94.6% and 87.1% of the time. Overall survival and disease-specific survival at 5 years were 93% and 99%, respectively. Local recurrence was associated with incomplete resection, noncurative resection, and deep submucosal invasion.


Rotermund et al. (2022) conducted a systematic review and meta-analysis of recurrence rates after endoscopic resection of large colorectal polyps. The 12-month local recurrence rate decreased based on endoscopic resection technique, in the following order: EMR with no margin ablation, EMR with some margin ablation, EMR with all margins ablated, and ESD (lowest recurrence rate). Notably, no studies utilized ESD for polyps less than 20 mm. This review is limited by the few ESD studies that were included.


In 2022, Zeng et al. conducted a systematic review and meta-analysis of the efficacy and safety of ESD for dysplasia in individuals with ulcerative colitis. A total of 192 individuals had 203 dysplastic lesions, averaging 26.7 mm in size. The en bloc, R0 resection, and curative resection rates are as follows: 94%, 84%, and 81%, respectively. Bleeding and perforation prevalences were 8% and 6%, respectively.


In 2021, Vaganov et al. conducted a systematic review and meta-analysis comparing ESD and EMR of colorectal tumors. The review included eight studies and 1989 tumors. There was no statistical difference in tumor size treated by each procedure, although the average ESD-treated tumors were larger in all but one study. En bloc resection was significantly higher among ESD-treated tumors (91% vs. 48%), and R0 resection rate was significantly higher as well (85% vs. 40%). Bleeding was similar between the treatment groups, but perforation was higher among ESD-treated individuals. Local recurrence was higher in the EMR treatment group.


Lim et al. (2021) conducted a meta-analysis and meta-regression of ESD versus EMR of colorectal polyps. A total of 281,344 polyps from 21 studies were included. En bloc resection and R0 resection rates were higher among the ESD-treated polyps, with a significant increase in procedure time. Perforation in ESD-treated individuals was greater in the ESD group, but there was no difference in bleeding. Further, recurrence in the ESD group was lower than the EMR group. Right colonic polyps were correlated with an increased risk in perforation when treated with ESD, but no other covariate was correlated with any outcome.


References

Agrawal R, Yang J, Ali S, et al. Safety and efficacy of endoscopic submucosal dissection in the management of gastric tube cancers after esophagectomy: a systematic review. Cureus. 2023;15(6):e40526.


Amin MB, Greene FL, Edge SB, et al. The Eighth Edition AJCC Cancer Staging Manual: Continuing to build a bridge from a population-based to a more "personalized" approach to cancer staging. CA Cancer J Clin. 2017;67(2):93-99.


ASGE standards of practice committee; Forbes N, Elhanafi SE, et al. American Society for Gastrointestinal Endoscopy guideline on endoscopic submucosal dissection for the management of early esophageal and gastric cancers: summary and recommendations. Gastrointest Endosc. 2023;98(3):271-284.


Association Japanese Gastric Cancer. Japanese Classification of Gastric Carcinoma. 15. Tokyo: Kanehara Shuppan; 2017.


Benites-Goñi H, Palacios-Salas F, Marín-Calderón L, et al. Short-term outcomes of endoscopic submucosal dissection for the treatment of superficial gastric neoplasms in non-Asian countries: a systematic review and meta-analysis. Ann Gastroenterol. 2023;36(2):167-177.


Buchner AM, Huang RJ, Lauwers GY, El-Serag HB. AGA Clinical Practice Update on Management of Gastric Polyps: Expert Review. Clin Gastroenterol Hepatol. 2026;24(4):893-905.


Dinis-Ribeiro M, Libânio D, Uchima H, et al. Management of epithelial precancerous conditions and early neoplasia of the stomach (MAPS III): European Society of Gastrointestinal Endoscopy (ESGE), European Helicobacter and Microbiota Study Group (EHMSG) and European Society of Pathology (ESP) Guideline update 2025. Endoscopy. 2025;57(5):504-554.


Doumbe-Mandengue P, Pellat A, Terris B, et al. Endoscopic submucosal dissection for early esophagogastric junction adenocarcinomas: a systematic review. Ann Gastroenterol. 2022;35(4):351-361.


Ferlitsch M, Hassan C, Bisschops R, et al. Colorectal polypectomy and endoscopic mucosal resection: European Society of Gastrointestinal Endoscopy (ESGE) Guideline - Update 2024. Endoscopy. 2024;56(7):516-545.


Haggitt RC, Glotzbach RE, Soffer EE, Wruble LD. Prognostic factors in colorectal carcinomas arising in adenomas: implications for lesions removed by endoscopic polypectomy. Gastroenterology. 1985;89(2):328-336.


Han C, Sun Y. Efficacy and safety of endoscopic submucosal dissection versus endoscopic mucosal resection for superficial esophageal carcinoma: a systematic review and meta-analysis. Dis Esophagus. 2021;34(4):doaa081.


Hewett DG, Kaltenbach T, Sano Y, et al. Validation of a simple classification system for endoscopic diagnosis of small colorectal polyps using narrow-band imaging. Gastroenterology. 2012;143(3):599-607.e1.


Huh CW, Ma DW, Kim BW, Kim JS, Lee SJ. Endoscopic Submucosal Dissection versus Surgery for Undifferentiated-Type Early Gastric Cancer: A Systematic Review and Meta-Analysis. Clin Endosc. 2021;54(2):202-210.


Ishihara R, Arima M, Iizuka T, et al. Endoscopic submucosal dissection/endoscopic mucosal resection guidelines for esophageal cancer. Dig Endosc. 2020;32(4):452-493.


Kaltenbach T, Anderson JC, Burke CA, et al. Endoscopic Removal of Colorectal Lesions: Recommendations by the US Multi-Society Task Force on Colorectal Cancer. Am J Gastroenterol. 2020;115(3):435-464.


Kikuchi R, Takano M, Takagi K, et al. Management of early invasive colorectal cancer. Risk of recurrence and clinical guidelines. Dis Colon Rectum. 1995;38(12):1286-1295.


Kitagawa Y, Ishihara R, Ishikawa H, et al. Esophageal cancer practice guidelines 2022 edited by the Japan esophageal society: part 1. Esophagus. 2023;20(3):343-372.


Kudo S, Tamura S, Nakajima T, Yamano H, Kusaka H, Watanabe H. Diagnosis of colorectal tumorous lesions by magnifying endoscopy. Gastrointest Endosc. 1996;44(1):8-14.


Lim XC, Nistala KRY, Ng CH, et al. Endoscopic submucosal dissection vs endoscopic mucosal resection for colorectal polyps: A meta-analysis and meta-regression with single arm analysis. World J Gastroenterol. 2021;27(25):3925-3939.


Liu Z, Zhao R. Endoscopic Submucosal Dissection vs. Surgery for Superficial Esophageal Squamous Cancer: A Systematic Review and Meta-Analysis. Front Oncol. 2022;12:816832.


Malik TF, Sabesan V, Mohan BP, et al. Efficacy and safety of endoscopic submucosal dissection for colorectal dysplasia in patients with inflammatory bowel disease: a systematic review and meta-analysis. Clin Endosc. 2024;57(3):317-328.


Mine S, Tanaka K, Kawachi H, et al. Japanese Classification of Esophageal Cancer, 12th Edition: Part I. Esophagus. 2024;21(3):179-215.


National Comprehensive Cancer Network. Esophageal and Esophagogastric Junction Cancers. Version 3.2026. Accessible at: https://www.nccn.org/professionals/physician_gls/pdf/esophageal.pdf. Accessed June 11, 2026.


National Comprehensive Cancer Network. Gastric Cancer. Version 3.2026. Accessible at: https://www.nccn.org/professionals/physician_gls/pdf/gastric.pdf. Accessed June 11, 2026.


Ngamruengphong S, Othman MO, Wang AY, Yang D. AGA Clinical Practice Update on Endoscopic Resection for Early Colorectal Cancer: Commentary. Gastroenterology. 2025;169(7):1558-1564.

Nishizawa T, Ueda T, Ebinuma H, Toyoshima O, Suzuki H. Long-Term Outcomes of Endoscopic Submucosal Dissection for Colorectal Epithelial Neoplasms: A Systematic Review. Cancers (Basel). 2022;15(1):239.


Ono H, Yao K, Fujishiro M, et al. Guidelines for endoscopic submucosal dissection and endoscopic mucosal resection for early gastric cancer (second edition). Dig Endosc. 2021;33(1):4-20.


Park CH, Yang DH, Kim JW, et al. Clinical Practice Guideline for Endoscopic Resection of Early Gastrointestinal Cancer. Clin Endosc. 2020;53(2):142-166.


Pimentel-Nunes P, Libânio D, Bastiaansen BAJ, et al. Endoscopic submucosal dissection for superficial gastrointestinal lesions: European Society of Gastrointestinal Endoscopy (ESGE) Guideline - Update 2022. Endoscopy. 2022;54(6):591-622.


Radadiya D, Desai M, Patel H, et al. Endoscopic submucosal dissection and endoscopic mucosal resection for Barrett's-associated neoplasia: a systematic review and meta-analysis of the published literature. Endoscopy. 2024;56(12):940-954.


Rice TW, Patil DT, Blackstone EH. 8th edition AJCC/UICC staging of cancers of the esophagus and esophagogastric junction: application to clinical practice. Ann Cardiothorac Surg. 2017;6(2):119-130.


Rotermund C, Djinbachian R, Taghiakbari M, Enderle MD, Eickhoff A, von Renteln D. Recurrence rates after endoscopic resection of large colorectal polyps: A systematic review and meta-analysis. World J Gastroenterol. 2022;28(29):4007-4018.


Rubenstein JH, Sawas T, Wani S, et al. AGA Clinical Practice Guideline on Endoscopic Eradication Therapy of Barrett's Esophagus and Related Neoplasia. Gastroenterology. 2024;166(6):1020-1055.


Sano Y, Tanaka S, Kudo SE, et al. Narrow-band imaging (NBI) magnifying endoscopic classification of colorectal tumors proposed by the Japan NBI Expert Team. Dig Endosc. 2016;28(5):526-533.


Singh RR, Nanavati J, Gopakumar H, Kumta NA. Colorectal endoscopic submucosal dissection in the West: A systematic review and meta-analysis. Endosc Int Open. 2023;11(11):E1082-E1091.


Vaganov YE, Nagudov MA, Khomyakov EA, Achkasov SI. Endoscopic submucosal dissection versus endoscopic mucosal resection for colorectal tumors: a systematic review and meta-analysis. Dissektsiya v podslizistom sloe i mukozektomiya v lechenii epitelial'nykh novoobrazovanii tolstoi kishki. Sistematicheskii obzor literatury i metaanaliz. Khirurgiia (Mosk). 2021;(9):77-84.


Vogel JD, Felder SI, Bhama AR, et al. The American Society of Colon and Rectal Surgeons Clinical Practice Guidelines for the Management of Colon Cancer. Dis Colon Rectum. 2022;65(2):148-177.


Wang HY, Zeng X, Bai SY, et al. The safety and efficacy of endoscopic submucosal dissection for treating early oesophageal carcinoma: a meta-analysis. Ann R Coll Surg Engl. 2020;102(9):702-711.


Wang N, Shu L, Liu S, et al. Comparing endoscopic mucosal resection with endoscopic submucosal dissection in colorectal adenoma and tumors: Meta-analysis and system review. PLoS One. 2023;18(9):e0291916.


Yang HJ, Kim JH, Kim NW, Choi IJ. Comparison of long-term outcomes of endoscopic submucosal dissection and surgery for undifferentiated-type early gastric cancer meeting the expanded criteria: a systematic review and meta-analysis. Surg Endosc. 2022;36(6):3686-3697.


Yeh JH, Huang RY, Lee CT, et al. Long-term outcomes of endoscopic submucosal dissection and comparison to surgery for superficial esophageal squamous cancer: a systematic review and meta-analysis. Therap Adv Gastroenterol. 2020;13:1756284820964316.


Zeng QS, Zhao ZJ, Nie J, et al. Efficacy and Safety of Endoscopic Submucosal Dissection for Dysplasia in Ulcerative Colitis Patients: A Systematic Review and Meta-Analysis. Gastroenterol Res Pract. 2022;2022:9556161.


Zhao J, Sun Z, Liang J, Guo S, Huang D. Endoscopic Submucosal Dissection for Early Gastric Cancer in Elderly vs. Non-Elderly Patients: A Systematic Review and Meta-Analysis. Front Oncol. 2022;11:718684.


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Coding

CPT Procedure Code Number(s)
THE FOLLOWING PROCEDURE CODE REPRESENTS ENDOSCOPIC SUBMUCOSAL DISSECTION OF ESOPHAGEAL SQUAMOUS CELL CARCINOMA, ESOPHAGEAL DYSPLASIA, EARLY STAGE ESOPHAGEAL ADENOCARCINOMA AND BARRETT ESOPHAGUS DYSPLASIA

43499​

​THE FOLLOWING PROCEDURE CODE REPRESENTS ENDOSCOPIC SUBMUCOSAL DISSECTION OF GASTRIC LESIONS SUGGESTIVE OF EARLY ADENOCARCINOMA

43999 ​

THE FOLLOWING PROCEDURE CODES REPRESENT ENDOSCOPIC SUBMUCOSAL DISSECTION OF COLORECTAL LESIONS

45399, 45999

ICD - 10 Procedure Code Number(s)
N/A

ICD - 10 Diagnosis Code Number(s)

C15.3 Malignant neoplasm of upper third of esophagus

C15.4 Malignant neoplasm of middle third of esophagus

C15.5 Malignant neoplasm of lower third of esophagus

C15.8 Malignant neoplasm of overlapping sites of esophagus

C16.0 Malignant neoplasm of cardia

C16.1 Malignant neoplasm of fundus of stomach

C16.2 Malignant neoplasm of body of stomach

C16.3 Malignant neoplasm of pyloric antrum

C16.4 Malignant neoplasm of pylorus

C16.5 Malignant neoplasm of lesser curvature of stomach, unspecified

C16.6 Malignant neoplasm of greater curvature of stomach, unspecified

C16.8 Malignant neoplasm of overlapping sites of stomach

C18.0 Malignant neoplasm of cecum

C18.2 Malignant neoplasm of ascending colon

C18.3 Malignant neoplasm of hepatic flexure

C18.4 Malignant neoplasm of transverse colon

C18.5 Malignant neoplasm of splenic flexure

C18.6 Malignant neoplasm of descending colon

C18.7 Malignant neoplasm of sigmoid colon

C18.8 Malignant neoplasm of overlapping sites of colon

C19 Malignant neoplasm of rectosigmoid junction

C20 Malignant neoplasm of rectum

D00.1 Carcinoma in situ of esophagus

D00.2 Carcinoma in situ of stomach

D01.0 Carcinoma in situ of colon

D01.1 Carcinoma in situ of rectosigmoid junction

D01.2 Carcinoma in situ of rectum

K22.710 Barrett's esophagus with low grade dysplasia

K22.711 Barrett's esophagus with high grade dysplasia

K22.81 Esophageal polyp

K22.82 Esophagogastric junction polyp

K31.7 Polyp of stomach and duodenum

K62.1 Rectal polyp

K63.5 Polyp of colon


HCPCS Level II Code Number(s)

C9779 Endoscopic submucosal dissection (ESD), including endoscopy or colonoscopy, mucosal closure, when performed


Revenue Code Number(s)
N/A


Coding and Billing Requirements


Policy History

Revisions From 11.03.18:
​09/02/2026
​The following policy has been reviewed and reissued to communicate the Company's continuing position on endoscopic submucosal dissection (ESD).​​
10/01/2025This version of the policy will become effective 10/01/2025.

The following new policy has been developed to communicate the Company's coverage criteria for endoscopic submucosal dissection (ESD).​

10/1/2025
10/1/2025
9/2/2026
11.03.18
Medical Policy Bulletin
Commercial
No