Process and Timeline for Device Manufacturers Seeking Assistance with Creating CPT Codes

The Heart Rhythm Society (HRS) welcomes the opportunity to engage with device manufacturers to assist with development of CPT codes for heart rhythm services and procedures, and health care providers.

HRS Policy for Device Manufacturer Requests to Facilitate a CPT Application

When a manufacturer seeks to obtain a new or revised Category I or Category III CPT code for emerging heart rhythm technologies, the manufacturer is advised to contact HRS.  HRS partners with the American College of Cardiology (ACC) and work closely with the AMA CPT Editorial Panel, the AMA/Specialty Society RBRVS Update Committee (RUC), and the Centers for Medicare & Medicaid Services (CMS) to ensure CPT codes are accurately presented and appropriately valued for reimbursement.

In order to comply with professional standards regarding lobbying activities, HRS requires that all initial requests and subsequent communications from device manufactures are sent directly to the Society’s CPT staff liaison (listed below) via email, rather than to the CPT advisors or leadership.

The cycle for establishing a CPT code typically spans between 12-24 months depending on the CPT publication calendar. The following guidelines have been developed to provide a timeline and framework for transparent, ethical engagement between HRS and the manufacturer, and to foster thoughtful and responsible decision making in a timely manner.

1. Contact the designated HRS CPT staff liaison to request a meeting to discuss the technology, reimbursement strategy and timing for a new code.
2. Provide a PowerPoint presentation or brief executive summary detailing the rationale for a new code(s), description of the service or procedure(s), clinical vignette, FDA approval status, and frequency of performance for current and future use, along with U.S. peer-reviewed clinical literature demonstrating the safety and effectiveness of the service or procedure.  This information  must be received by staff liaison at least 90 days prior to the intended application submission deadline to the AMA CPT Editorial Panel.
3. The staff liaison will schedule a meeting with the HRS CPT advisors and the manufacturer to present the technology and discuss the proposed coding strategy.
4. The CPT advisors will discuss the technology and proposed or alternative coding strategy with the Health Policy and Regulatory Affairs Committee, and solicit feedback.  At that time, HRS will choose to either:
   • Take ownership of the application and present it to the CPT Editorial Panel as a co-applicant with ACC; or,
   • Offer feedback about the proposed coding strategy to the manufacturer, and advise the manufacturer to submit and present the application to the CPT Editorial Panel.
5. Should HRS decide to take ownership, the manufacturer must provide a completed formal draft CPT Code Change Application to HRS for submission to the CPT Editorial Panel via the CPT SmartApp online system.
6. HRS will solicit endorsement of the application from ACC as a co-applicant.

Please note: HRS reserves the right to determine the timing for review of the request, contingent upon the nature and circumstances specific to the request, as well as other demands upon the Society. Manufacturers are not allowed to be co-applicants or co-presenters to the CPT Editorial Panel. Guidance provided by HRS should not be construed as endorsement of the proposal unless the Society agrees to take ownership of the application.  After an application is submitted, HRS physician advisors and staff are expected to follow confidentiality rules instituted by the AMA CPT process.

Communication with HRS, Committee Members, and CPT Advisors

HRS relies upon physician volunteers to serve on its committees and in specific roles such as Primary CPT Advisor and Alternate CPT Advisor to the American Medical Association.  These physicians are selected to represent the HRS membership.  Their volunteer work and advocacy on behalf of HRS are focused on advancing the goals of the HRS membership, society, and promoting care.  While alignment between these goals and our collaborating manufacturers is often present, there will be times they diverge.  We ask that you respect these responsibilities in all cases, whether alignment is or is not fully present.

In addition, it is requested that all communication and correspondence regarding proposals, follow-up, feedback, etc. be channeled through the HRS staff liaison.  In person meetings, phone calls and virtual meetings should also be coordinated through HRS staff.

HRS CPT Staff Liaison
Lisa Miller, MS
Senior Director, Health Policy and Reimbursement
Email: [email protected]