Comments to CMS on Transcatheter Tricuspid Valve Replacement (TTVR) and Broader CED Policy Considerations

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Editor’s note: The attached comment letter was submitted to the Centers for Medicare and Medicaid Services (CMS) on July 18, 2024.

As authors of “A Roadmap for Improving Medicare’s Application of Coverage With Evidence Development” recently published in Value in Health, we are writing to comment on the National Coverage Analysis (NCA) for Transcatheter Tricuspid Valve Replacement (TTVR) and, more broadly, on the application of the Coverage with Evidence Development (CED) policy. The principles outlined in the tracking sheet for this NCA align with several key recommendations we made for improving CED policy across all cases.

Recommendations discussed in the letter include clarifying the process for ending CED requirements, adopting clear criteria for applying CED, prioritizing patient preferences and timely and equitable access, and minimizing the burden on providers and patients.

Read the full comment letter here.

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