Cardiology Coding Alert

Reader Question:

33361 Now Appears in CMS's TAVR Policy

Question: Does the creation of the new TAVR codes change Medicare’s coverage policy for the procedure?

Virginia Subscriber

Answer: Medicare has updated its policy. See Transmittal 2628, CR 8168, at www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/Downloads/R2628CP.pdf.

The Transmittal, dated Jan.7, 2013, includes the new 2013 codes for transcatheter aortic valve replacement (TAVR):

33361, Transcatheter aortic valve replacement (TAVR/TAVI) with prosthetic valve; percutaneous femoral artery approach

33362, … open femoral artery approach

33363, … open axillary artery approach

33364, … open iliac artery approach

33365, … transaortic approach (e.g., median sternotomy, mediastinotomy)

0318T, Implantation of catheter-delivered prosthetic aortic heart valve, open thoracic approach, (e.g., transapical, other than transaortic).

The Transmittal also includes clarifications for the previously placed policy:

For non-FDA-approved indications, the patient must be enrolled in a qualifying clinical study posted at www.cms.gov/Medicare/Coverage/Coverage-with-Evidence-Development/Transcatheter-Aortic-Valve-Replacement-TAVR-.html

To meet National Coverage Determination (NCD) requirements, an interventional cardiologist and a cardiothoracic surgeon must both participate in the operation, so you must bill TAVR codes with modifier 62 (Two surgeons)

For Medicare Advantage (MA) plan participants, the MA plan is accountable for payment. Medicare’s TAVR coverage is included under the "Routine Costs in Clinical Trials" NCD, and "it is in these trials that the fee-for-service (FFS) system is responsible for payment."

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