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View Public Comments for Implantable Cardioverter Defibrillators (CAG-00157R4)

Collins, Jim
CardiologyCoder.Com, Inc.

I work extensively with cardiologists nationwide to help them accurately document, code, and bill for their services.

I encourage CMS to include coverage for defibrillator generator change outs when devices reach their elective replacement interval (ERI). This is the point at which physicians have a few months to schedule and facilitate a generator change before they can no longer rely on the device to function properly.

Generator change out is not currently a covered indication. This can be problematic, especially with biventricular systems and systems that employ His bundle pacing. These systems can improve the patient's ejection fraction and heart failure classification to the point that the patient no longer meets the coverage requirements of an ejection fraction of 35% or less and class II, III, or IV heart failure.

Generator change out was adopted as a covered indication for pacemakers by each of the Medicare Administrative Contractors. The NCD for defibrillators does not address generator change out.