Comment Letters | Heart Rhythm Society

Comment Letters

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

HRS Urges CMS to Clarify Shared Decision-Making Requirement for LAAC

Comment Letters (Regulatory Agencies)
Comment Letters (Reimbursement)

June 28, 2023 - On June 28th, the Heart Rhythm Society, the Society for Cardiovascular Angiography & Interventions, and the American College of Cardiology sent a letter to the Centers for Medicare & Medicaid Services regarding misinterpretation of the National Coverage Determination shared decision-making requirement for percutaneous left atrial appendage closure. View Comment Letter

HRS Joins Letter Urging Caution on EPA Proposal to Regulate Ethylene Oxide

Comment Letters (Regulatory Agencies)
Comment Letters (Reimbursement)

June 27, 2023 - HRS joins the American College of Cardiology, the Society for Cardiovascular Angiography & Interventions, the Society of Interventional Radiology, and the Society of Thoracic Surgeons in a letter to the Environmental Protection Agency (EPA) urging the agency to work with the FDA and public stakeholders to implement updated national standards for device sterilization facilities. View Comment Letter

HRS Voices Support for Expansion of GME Legislation

Comment Letters (Regulatory Agencies)
Comment Letters (Reimbursement)

May 22, 2023 - The Heart Rhythm Society, and nearly 80 organizations, sent letters to the House and Senate leaders in support of the Resident Physician Shortage Reduction Act (S. 1302). The need for physicians continues to grow, and this bipartisan legislation is crucial to expanding the physician workforce. If passed, the legislation will gradually raise the number of Medicare-supported GME positions by 2,000 per year for seven years, for a total of 14,000 new slots.

HRS Signs Letter of Support for Legislation to Stabilize Medicare Physician Payment

Comment Letters (Regulatory Agencies)
Comment Letters (Reimbursement)

April 24, 2023 - HRS and more than 100 national and state medical societies commended House of Representatives Raul Ruiz, Larry Bucshon, Ami Bera, and Mariannette Miller-Meeks for introducing the Strengthening Medicare for Patients and Providers Act (H.R. 2474 ). If passed, the bill will stabilize Medicare physician payment by providing an annual inflation update based on the Medicare Economic Index. View Submitted Letter

HRS Urges Congress to Pass Legislation to Provide Physicians with an Annual Inflation-based Payment Update

Comment Letters (Regulatory Agencies)
Comment Letters (Reimbursement)

March 15, 2023 - The Heart Rhythm Society, along with more than 100 national and state medical societies, sent a letter to Congress calling for legislation to provide physicians with an annual inflation-based payment update tied to the full Medicare Economic Index (MEI). Unlike nearly all other Medicare providers and suppliers, physicians do not receive an annual inflationary payment update. If enacted, an annual inflation update would provide much needed fiscal stability for physician services. View Submitted Letter

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 | Read Follow Up Survey Responses

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.

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