Comment Letters | Heart Rhythm Society

Comment Letters

Read HRS' Comment Letters on a variety of coverage and reimbursement topics.

HRS Survey Assessing Impact of Cuts to Ablation Reimbursement in the US

Comment Letters (Reimbursement)

On January 1, 2022, the U.S. Centers for Medicare & Medicaid Services (CMS) implemented drastic payment cuts for commonly performed electrophysiology ablation procedures, including ablations for atrial fibrillation (AF) and supraventricular tachycardia (SVT), despite objections from the Heart Rhythm Society (HRS) and others. To understand the real-world impact of the payment cuts on physician practices, a survey was conducted. Download the survey results.

Read the full article on Heart Rhythm Journal

Characteristics of a Rational Medicare Payment System

Comment Letters (Reimbursement)

May 27, 2022. The Heart Rhythm Society, along with the American Medical Association, and more than 100 other national and state medical societies have endorsed a set of guiding principles for payment reform, Characteristics of a Rational Medicare Physician Payment System.  The principals provide a framework to develop policy proposals that will stabilize payment for physician services. Work to develop concrete proposals to meet these goals will continue.

HRS Comments on Plans to Improve Medicare Access to New Technologies

Comment Letters (Reimbursement)

April 14, 2021 - On April 13, HRS submitted comments to the Centers for Medicare and Medicaid Services (CMS) urging the Agency to move forward with plans to allow for Medicare coverage of procedures that the FDA identifies as breakthrough technology. The Medicare Coverage of Innovative Technology program is intended to establish a pathway to provide Medicare beneficiaries access to new, innovative devices.

HRS Comments on FDA’s 2020 Guidance Priorities

Comment Letters (Reimbursement)

November 13, 2019 - The Food and Drug Administration’s (FDA) Center for Devices and Radiological Health (CDRH) has released its final and draft guidance publication priorities for the 2020 fiscal year. The Heart Rhythm Society submitted comments on (1) the inclusion of the development of a draft guidance document titled Content of Premarket Submissions for Management of Cybersecurity in Medical Devices as a Category A document; and (2) the necessity for an update of the 1990 document titled Implantable Pacemaker Testing Guidance.

Proposed Revisions to Medicare's Quality Payment Program for CY 2020

Comment Letters (Reimbursement)
Medicare Fee Schedules

September 19, 2019 - HRS submitted it comments on the proposed revisions to the Medicare Quality Payment Program for 2020. Recommendations addressed efforts to streamline the Merit-Based Incentive Payment System, promoting the use of specialty measures relevant to EP, and interoperability.

2020 Medicare Physician Fee Schedule

Comment Letters (Reimbursement)
Medicare Fee Schedules

September 9, 2019 - Read our comment letter to the Centers for Medicare and Medicaid Services on the Proposed Medicare Physician Fee Schedule for 2020. In the comment letter, HRS recommends corrections that would improve payment for the malpractice RVUs allocated to EP services, and address CMS' questions regarding payments for remote monitoring services.