Comment Letters | Heart Rhythm Society

Comment Letters

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

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The Food and Drug Administration’s (FDA) Center for Devices and Radiological Health (CDRH) has released its final and draft guidance publication priorities for the 2020 fiscal year. The Heart Rhythm Society submitted comments on (1) the inclusion of the development of a draft guidance document titled Content of Premarket Submissions for Management of Cybersecurity in Medical Devices as a Category A document; and (2) the necessity for an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

Updated MRI National Coverage Policy

Coverage
Coverage Statements
Reimbursement
Comment Letters (Coverage)
Comment Letters (Reimbursement)
Comment Letters (Regulatory Agencies)

April 19, 2018 - On April 10, 2018, the Centers for Medicare and Medicaid Services (CMS) released an updated National Coverage Determination for Magnetic Resonance Imaging (MRI). The update allows coverage for MRI for certain patients with Cardiac Implanted Electronic Devices (CIEDs). 

Key Aspects of the Updated ICD Coverage Policy

Coverage
Coverage Statements
Reimbursement
Comment Letters (Coverage)
Comment Letters (Reimbursement)

February 15, 2018 - Following are the key aspects of the February 15, 2018 National Coverage Determination for ICDs. The changes are effective immediately, though Medicare Administrative Contractors must wait for further technical instructions from CMS before updating claims processing software.