New HCPCS Code C1609 for Motion-Preserving Vertebral Devices
Healthcare coding professionals must stay current with emerging technologies and the codes created to support accurate reporting and reimbursement. A recent addition to the HCPCS Level II code set highlights the growing adoption of motion-preserving spinal implants and introduces new coding considerations for facility outpatient billing.
Effective July 1, 2026, HCPCS Level II code C1609 (Vertebral device, motion-preserving, with screw fixation) became available for reporting specific spinal implant procedures involving the TOPS System. Understanding when and how to report this code is essential for coding accuracy and compliance.
What Is the TOPS System?
In June 2023, the U.S. Food and Drug Administration (FDA) approved the Total Posterior Spine (TOPS™) System, a spinal implant designed to preserve motion at the treated spinal segment.
Unlike traditional fusion procedures, the TOPS™ System allows movement in multiple directions, including:
Flexion
Extension
Lateral bending
Axial rotation
At the same time, the device is designed to block shear forces that can negatively affect the lower spine, particularly in patients with conditions such as spondylolisthesis.
New HCPCS Level II Code C1609
To support reporting of this technology in the hospital outpatient setting, CMS established:
C1609
Vertebral device, motion-preserving, with screw fixation
This HCPCS Level II code may be assigned when the TOPS™ System implant is used during an eligible outpatient procedure.
Required CPT Category III Code
When reporting implantation of the TOPS™ System, HCPCS code C1609 should be reported in conjunction with the following CPT Category III code:
0202T
Posterior vertebral joint(s) arthroplasty (e.g., facet joint[s] replacement), including facetectomy, laminectomy, foraminotomy, and vertebral column fixation; injection of bone cement, when performed; including fluoroscopy; single level, lumbar spine.
Because the HCPCS code identifies the implant itself, it is not a substitute for reporting the surgical procedure. Both codes are necessary when applicable for facility billing.
Understanding the Facility vs. Professional Coding Distinction
One area that can create confusion is the difference between facility and professional reporting requirements.
CMS uses HCPCS Level II “C” codes to enable hospitals to report emerging technologies and receive reimbursement for Medicare outpatient services in a timely manner. These codes are intended for facility billing purposes and are generally not appropriate for physician professional claims.
For Single Path Coders responsible for both facility and professional coding, understanding this distinction is critical.
Medicare Outpatient Coding Scenario
When a Medicare hospital outpatient undergoes implantation of the TOPS™ System, the following coding should be reported as appropriate:
Facility Coding
0202T
C1609*
Professional Coding
0202T
*When the facility purchases the spinal implant for outpatient surgery on a Medicare beneficiary, the facility should report HCPCS code C1609 in addition to the appropriate procedure code.
Why This Update Matters
The introduction of C1609 provides a reporting mechanism for a newer motion-preserving spinal implant technology in the outpatient setting. Coding teams should review existing workflows to ensure:
Appropriate identification of TOPS System implants
Correct assignment of HCPCS code C1609 when applicable
Proper distinction between facility and professional billing requirements
Accurate reporting of CPT Category III code 0202T alongside the device code
As new technologies continue to enter clinical practice, coding professionals play a critical role in ensuring accurate documentation, reporting, and reimbursement.
Key Takeaways
HCPCS Level II code C1609 became effective July 1, 2026.
The code identifies a motion-preserving vertebral device with screw fixation, including the TOPS System implant.
C1609 should be reported with CPT Category III code 0202T when applicable.
HCPCS Level II “C” codes are intended for facility billing, not professional physician reporting.
For Medicare hospital outpatient cases involving the TOPS™ System, facilities may report both 0202T and C1609, while physicians report 0202T
Conclusion
The addition of HCPCS code C1609 reflects the continued evolution of spinal surgery technologies and the coding systems that support them. Coding professionals should familiarize themselves with the reporting requirements for the TOPS™ System and ensure that facility and professional claims are coded appropriately. Staying informed about new code releases helps support coding accuracy, compliance, and appropriate reimbursement.