SCAI Members, 

Last month, the Centers for Medicare & Medicaid Services (CMS) released its Proposed Decision Memo for the Transcatheter Aortic Valve Replacement (TAVR) National Coverage Determination (NCD). This opened a public comment period that ends July 15, 2026. In my last message, we looked at the key changes and how they compared with our member survey. Now is the time for us to ensure our voices are heard. 

SCAI is preparing formal comments to CMS, and we encourage members to submit individual comments as well. Please use the comment template below to share your perspective by describing your practice and how the proposed changes may affect patients.

Template to Comment on Proposed Decision Memo for Transcatheter Aortic Valve Replacement (TAVR) (CAG-00430R2) 

CMS responds best to unique, personal responses. The talking points below can be used to help draft your comment letter. Be sure to describe your practice and how the changes to the NCD will affect your patients. Any personal examples you can give strengthen the points made. We recommend encouraging CMS to finalize this decision memo as proposed, with the clarifications listed below. 

Heart Team 

• Collaboration is essential 
• Initial evaluations must include both IC and surgeon members of team 
• Visit flexibility, such as telehealth, is critical 

Operator Requirements  

• Support CMS’s recommendation to remove the mandatory two-operator requirement 
• Recommend clarification in the language to specify TAVR be conducted by a single or two qualified operators, who may include an interventional cardiologist and/or cardiac surgeon 
• Composition of the operative team should be determined by the local heart team
• Justification should not be required for teams of two operators to be covered 

Coverage for Other Indications 

• CED is an appropriate avenue for other indications that have less evidence than severe AS 
• Other indications that should be covered include: 
  • Aortic regurgitation 
  • Severe bicuspid stenosis 
  • Symptomatic moderate AS 

Continuous Quality Improvement 

• Should include registry reporting 

Comments are due to CMS on July 15 at the TAVR NCD website. Please reach out with any questions or feedback at [email protected] or on MySCAI. 

Thank you to those who have participated so far via our member survey, town hall, and email. Your contributions help ensure that the interventional cardiology community has a strong voice in this process.