Chimeric antigen receptor T-cell (CAR-T) therapy has moved from a last-resort experimental approach to an established treatment option across multiple hematologic malignancies. Seven autologous CAR-T products are now FDA-approved, targeting CD19 or BCMA in diffuse large B-cell lymphoma (DLBCL), follicular lymphoma (FL), mantle cell lymphoma (MCL), acute lymphoblastic leukemia (ALL), and multiple myeloma (MM).
The access landscape is defined by high per-patient cost ($373,000–$475,000 WAC), complex manufacturing logistics, a Medicare National Coverage Determination (NCD 110.24), and the recent elimination of REMS requirements. A new challenge has emerged: how to sequence CAR-T relative to bispecific antibodies in multiple myeloma, where both classes target BCMA.
This guide covers every FDA-approved CAR-T product, payer coverage requirements, billing and coding, the REMS elimination, and what access teams should monitor next.
Who this is for
Oncology market access teams, cell therapy coordinators, hospital pharmacy leaders, billing and coding staff, and payer-facing professionals who need a source-cited reference for navigating CAR-T reimbursement and coverage in 2026.
All seven FDA-approved CAR-T products
CD19-targeted products (lymphoma and ALL)
| Product | Generic | Manufacturer | Key FDA indications | WAC (approx.) | HCPCS |
|---|---|---|---|---|---|
| Kymriah | Tisagenlecleucel | Novartis | ALL (up to age 25, 2L+); DLBCL (2L+); FL (2L+) | $475,000 (ALL); $373,000 (DLBCL) | Q2040 |
| Yescarta | Axicabtagene ciloleucel | Kite/Gilead | LBCL (2L+; 1L refractory/early relapse); FL (2L+); MZL (2L+) | $503,580 | Q2041 |
| Tecartus | Brexucabtagene autoleucel | Kite/Gilead | MCL (R/R); B-cell precursor ALL (R/R, adults) | $462,000 | Q2043 |
| Breyanzi | Lisocabtagene maraleucel | BMS/Juno | LBCL (2L+); FL (2L+); MCL (2L+) | $410,300 | Q2044 |
| Aucatzyl | Obecabtagene autoleucel | Autolus | B-cell precursor ALL (R/R, adults) | ~$460,000 | Pending |
BCMA-targeted products (multiple myeloma)
| Product | Generic | Manufacturer | Key FDA indications | WAC (approx.) | HCPCS |
|---|---|---|---|---|---|
| Abecma | Idecabtagene vicleucel | BMS/Celgene | R/R MM after 2L+ including PI, IMiD, anti-CD38 | $419,500 | Q2054 |
| Carvykti | Ciltacabtagene autoleucel | J&J/Legend | R/R MM after 1L+ including PI and IMiD, refractory to lenalidomide | $465,000 | Q2056 |
REMS elimination: what changed
On June 27, 2025, the FDA removed the Risk Evaluation and Mitigation Strategy (REMS) requirements for all six autologous CAR-T therapies (the requirement was lifted before Aucatzyl's November 2024 approval, which never had REMS). This was a significant access development:
Before REMS elimination: Treatment centers had to be certified under the REMS program, maintain specific training and credentialing, and use the KX modifier on Medicare claims to confirm REMS facility enrollment.
After REMS elimination: CMS issued a transmittal (December 2025, effective June 26, 2025, implementation date February 6, 2026) instructing Medicare Administrative Contractors (MACs) to no longer require the KX modifier on CAR-T claims.
While REMS removal reduces the administrative burden, the underlying requirement for centers experienced in hematopoietic stem cell transplantation and cellular immunotherapy remains embedded in NCD 110.24 and clinical practice guidelines from the American Society for Transplantation and Cellular Therapy (ASTCT).
Medicare coverage: NCD 110.24
CMS's National Coverage Determination (NCD 110.24) provides the framework for Medicare coverage of CAR-T therapy:
Coverage scope: Autologous T-cells expressing at least one CAR, when administered at a healthcare facility that is (or was) enrolled in the FDA REMS program (or meets equivalent standards after REMS elimination).
FDA-approved uses: Covered when the CAR-T product is used for its FDA-approved indication.
Off-label and investigational uses: Covered only in the context of a CMS-approved clinical trial under NCD 310.1.
Medicare Advantage (Part C): CMS requires MA plans to provide the same coverage as FFS Medicare under the NCD, though MA plans may impose additional requirements such as prior authorization.
IPPS reimbursement for FY 2026
CAR-T cases billed under Medicare's Inpatient Prospective Payment System (IPPS) are grouped under MS-DRG 018 (Chimeric Antigen Receptor T-cell and Other Immunotherapies). For FY 2026, CMS finalized several policy changes:
Base payment rate: The proposed base payment for CAR-T cases increased by 16.8% to approximately $314,231.
Outlier threshold: The fixed-loss threshold decreased to $40,397 (a 13% decrease from FY 2025), making it easier for high-cost CAR-T cases to qualify for additional outlier payments.
Clinical trial adjustment: CMS lowered reimbursement rates for CAR-T therapies provided as part of clinical trials, acknowledging that trial costs are partially offset by sponsor funding.
A significant policy change starting in FY 2026: CMS now bundles preparatory procedures for patient-specific cell procurement (including leukapheresis) into the product payment rather than reimbursing them separately. This reduces itemized billing flexibility but simplifies the overall claim structure.
These IPPS changes are important because the real-world total cost of CAR-T treatment — including apheresis, manufacturing, hospitalization, ICU care for CRS and ICANS management, and follow-up — can reach $1 million or more per patient, well above the list price of the therapy itself. Even with the FY 2026 base rate increase to $314,231, many treatment centers report that CAR-T cases operate at a financial loss after accounting for total costs, particularly for centers serving predominantly Medicare populations. The median out-of-pocket copayment for patients is approximately $510.
Prior authorization and payer coverage
What payers require
Prior authorization for CAR-T therapy is essentially universal. Common requirements include:
Diagnosis confirmation. Pathology-confirmed diagnosis matching the FDA-approved indication for the requested CAR-T product.
Prior therapy documentation. Number and type of prior lines of therapy, including specific drug classes required (e.g., proteasome inhibitor, immunomodulatory agent, anti-CD38 antibody for myeloma CAR-T).
Disease status. Evidence of relapsed or refractory disease, often with specific timing requirements (e.g., progression within 60 days of last therapy).
Performance status and organ function. ECOG performance status, LVEF, hepatic function, renal function, and hematologic parameters to confirm eligibility for lymphodepleting chemotherapy.
Center qualification. Documentation that the treatment center has experience with hematopoietic stem cell transplantation and cellular immunotherapy.
Commercial payer examples
UnitedHealthcare/Optum's clinical guideline for CAR-T therapy (Chimeric Antigen Receptor T-Cell Therapy, updated 2026) defines medical necessity criteria for each product by indication, with specific prior line-of-therapy requirements. The guideline references the FDA label and NCCN compendium recommendations.
Highmark's medical policy covers CAR-T for FDA-approved indications and also extends coverage to NCCN Category 1, 2A, or 2B recommended uses, as well as compendia-supported off-label indications.
Medicaid coverage
Medicaid coverage for CAR-T varies significantly by state. Some states cover CAR-T under their Medicaid state plan, while others require separate authorization. The ASTCT Coding and Billing Guide (updated March 2026) advises providers serving Medicaid patients to research state-specific benefit documents and Medicaid managed care medical policies.
HCPCS coding for CAR-T products and services
Product-specific codes
| Product | HCPCS Code | Description |
|---|---|---|
| Kymriah | Q2040 | Tisagenlecleucel, up to 600 million autologous anti-CD19 CAR-positive viable T cells |
| Yescarta | Q2041 | Axicabtagene ciloleucel, up to 200 million autologous anti-CD19 CAR-positive viable T cells |
| Tecartus | Q2043 | Brexucabtagene autoleucel |
| Breyanzi | Q2044 | Lisocabtagene maraleucel |
| Abecma | Q2054 | Idecabtagene vicleucel |
| Carvykti | Q2056 | Ciltacabtagene autoleucel |
| Aucatzyl | J9999 or J3590 | Unclassified (pending dedicated code) |
Procedure codes
| CPT Code | Description |
|---|---|
| 38225 | CAR-T therapy; leukapheresis and T-cell collection |
| 38226 | CAR-T therapy; preparation of blood-derived T lymphocytes for transportation (e.g., cryopreservation, storage) |
| 38227 | CAR-T therapy; receipt and preparation of CAR-T cells for administration |
| 38228 | CAR-T therapy; infusion of CAR-T cells |
ICD-10-PCS codes
CMS assigns specific ICD-10-PCS procedure codes for each CAR-T product, grouped under New Technology Group 7. These are used for inpatient claims grouped under MS-DRG 018.
CAR-T vs bispecific antibodies: the sequencing question
In multiple myeloma, both CAR-T (Abecma, Carvykti) and bispecific antibodies (Tecvayli, Elrexfio, Talvey, Lynozyfic) target BCMA (or GPRC5D for Talvey). A practical sequencing question has emerged:
CAR-T first offers the potential for treatment-free remission but requires specialized center access, manufacturing lead time (typically 3–6 weeks), and inpatient hospitalization.
Bispecific first offers immediate availability, administration in community oncology settings, and no manufacturing delay, but requires continuous treatment until progression.
Payer policies are beginning to address sequencing. Some payers require documentation of why CAR-T was not pursued before bispecific use, or conversely, why bispecific therapy was not attempted before CAR-T. The BCMA-targeting overlap means prior exposure to BCMA-directed bispecifics may affect subsequent CAR-T efficacy, an evolving clinical question.
What to monitor next
| Signal | Timeline | Access impact |
|---|---|---|
| Additional CAR-T indications (earlier lines) | 2026–2027 | Expanded patient volume, payer criteria updates |
| Outpatient CAR-T administration | 2026+ | Reimbursement methodology shift from IPPS to Part B |
| Allogeneic ("off-the-shelf") CAR-T approvals | 2026–2028 | Manufacturing timeline reduction, cost structure change |
| CAR-T biosimilar/follow-on competition | 2028+ | Price erosion, payer switching |
| Payer policies on CAR-T/bispecific sequencing | 2026 | Step therapy or medical necessity criteria |
| Aucatzyl dedicated HCPCS code | 2026–2027 | Billing simplification |
Sources
CMS. Medicare Claims Processing Manual, Chapter 32, Section 400. Change Request 13432, December 2025. Available at: cms.gov/files/document/r13432cp.pdf
CMS. National Coverage Determination Manual, Section 110.24. Autologous Treatment of Cancer with T-cells Expressing at Least One Chimeric Antigen Receptor (CAR). Available at: cms.gov
Avalere Health. New CAR-T Policies Affect Access, Reimbursement. FY 2026 IPPS Final Rule Analysis. Available at: advisory.avalerehealth.com
ASTCT. CAR-T Therapy Coding and Billing Guide. Updated March 2026. Available at: astct.org/car-t-coding-and-billing-guide
UnitedHealthcare/Optum. Clinical Guideline: Chimeric Antigen Receptor T-Cell (CAR-T) Therapy. Updated 2026. Available at: uhcprovider.com
BioInformant. Global Demand for CAR-T Cell Therapies by Product in 2026. Available at: bioinformant.com
HMPI. CAR-T Therapy: Escalating Costs in an Expanding Market. February 2026. Available at: hmpi.org
FDA. REMS Removal for Autologous CAR-T Therapies. June 27, 2025. Available at: fda.gov
FDA. Yescarta (axicabtagene ciloleucel) Prescribing Information. Kite Pharma / Gilead Sciences. Available at: dailymed.nlm.nih.gov
FDA. Carvykti (ciltacabtagene autoleucel) Prescribing Information. Janssen Biotech. Available at: dailymed.nlm.nih.gov
Carvykti Access and Reimbursement Guide. Janssen Biotech. Available at: carvyktihcp.com
Binaytara. CAR-T or Bispecific Antibodies First? A Practical Sequencing Guide for Relapsed Multiple Myeloma in 2026. Available at: binaytara.org
AJMC. It's Time to Reimagine Reimbursement for CAR T-Cell Therapy. Available at: ajmc.com
