As previously reported, SCAI submitted a letter on July 9, 2019 to the Centers for Medicare & Medicaid Services (CMS) seeking removal of an outdated National Coverage Determination believed to be thwarting access to catheter-based therapies to treat pulmonary embolism. In a follow-up to the July letter, SCAI secured a formal conference call held on November 22, 2019 with CMS Coverage Advisory Group (CAG) staff that included society staff and physician representatives from SCAI, SVM and SIR, Drs. Andrew Klein, Herb Aronow and Akhilesh Sista, respectively. Highlights stressed by the physician society representatives included, the following: 

• The Societies reiterate their recommendation for removal (retirement) of NCD 240.6
• The NCD is over 30 years old, does not provide an effective date, and there has been no instruction (coding guidance) provided to MACs as to how to implement the NCD
• It is unclear what technology the NCD is aimed at describing
• The existing NCD is causing confusion with some hospital compliance officers interpreting the NCD to be applicable to transcatheter arterial mechanical thrombectomy for pulmonary embolism thwarting access to care
• The societies have not received any complaints to date regarding claims denials for mechanical thrombectomy reported using existing code 37184 performed to treat pulmonary embolism
• The societies stressed that reconsideration of the NCD is not believed to be needed
  • Standards and guidelines for the treatment of pulmonary embolism are well-established with widespread adoption

     

  • Catheter-based mechanical thrombectomy for DVT and pulmonary embolism has become widely adopted and is not considered experimental

     

  • The only known barrier to access to these lifesaving treatments is the interpretation of the existing NCD by some hospital compliance officers

     

  • Utilization of CPT® code 37184 [Primary percutaneous transluminal mechanical thrombectomy, noncoronary, non-intracranial, arterial or arterial bypass graft, including fluoroscopic guidance and intraprocedural pharmacological thrombolytic injection(s); initial vessel] is below 10K and does not represent a significant impact to the Medicare Trust Fund

     

CMS CAG staff expressed appreciation for the societies and their summary of concerns. They confirmed that CMS has all the necessary data to proceed with removal and provided insight into the CMS NCD removal process. SCAI will monitor the CMS website for a notice of CMS’s intent to retire the NCD, which will trigger a 30-day public comment period.