TAVR for aortic regurgitation stays at MAC discretion while CMS NCA CAG-00430R3 takes comments to Oct 10

On September 10, 2026, the same day it finalized its aortic stenosis TAVR decision, CMS opened National Coverage Analysis CAG-00430R3 to reconsider NCD 20.32 for transcatheter aortic valve replacement in aortic regurgitation (AR). No proposed decision memo has been released, and the initial 30-day public comment period ends Saturday, October 10, 2026.

For a cardiology or facility coding desk, the more useful document right now is the September 10 final decision memo (CAG-00430R2). It says how AR cases are covered while this new analysis runs, and the answer isn't the aortic stenosis rules.

What CMS opened in CAG-00430R3

CMS internally generated the reconsideration. The tracking sheet lists the benefit categories as Inpatient Hospital Services and Physicians' Services, and it limits the scope in one line: "This NCA will only address indications for TAVR for AR."

CMS is soliciting public comment and says it is particularly interested in comments with scientific evidence, specifically peer-reviewed literature describing the role of TAVR for AR. Comments go through the blue Comment button on the tracking sheet, under CMS's public comment instructions. CMS says the 30-day period began with the September 10 posting and that it considers all public comments.

How TAVR for AR is covered right now

The aortic stenosis decision memo is explicit that AR is outside it. Its evidence review "addresses TAVR for AS. It does not address TAVR for the treatment of other conditions such as aortic regurgitation (AR)." CMS then lays out the interim path:

CMS also says, in its response to comments, that its omission of a clear explanation "created confusion and may have been perceived to establish noncoverage," and that it revised the final decision language and NCD manual language to reflect the AR position. If anyone on your team read the AS update as shutting AR off, the final memo says otherwise.

Why CMS split AR from the aortic stenosis decision

The tracking sheet ties the new analysis to two things. During the AS reconsideration, commenters asked CMS to clarify coverage of TAVR for AR, and some wanted the final NCD to address both AS and AR. And in March 2026, FDA approved the first TAVR system for AR, the Trilogy Transcatheter Heart Valve system manufactured by JenaValve, as stated on the sheet.

Instead of widening the AS analysis, CMS opened a separate one. The AS decision itself, covered in our September TAVR final decision story, removed CED for symptomatic severe AS and added CED coverage for asymptomatic severe AS. None of that sets the rules for an AR case.

CAG-00430R3 timeline

No proposed decision memo has been released yet. Until one is, there is no proposed national AR policy to code or bill against.

Keep AR and AS apart in the record and on the claim

Because AS and AR now sit on different coverage paths, the documented valve lesion carries more weight than usual. ICD-10-CM keeps them separate:

• I35.1 Nonrheumatic aortic (valve) insufficiency, and I06.1 Rheumatic aortic insufficiency, for regurgitation
• I35.2 Nonrheumatic aortic (valve) stenosis with insufficiency, and I06.2 Rheumatic aortic stenosis with insufficiency, when both are documented
• I35.0 Nonrheumatic aortic (valve) stenosis, for stenosis alone

These are code descriptors, not a CMS covered-code list. Neither the tracking sheet nor the AS memo publishes ICD-10-CM, CPT, or HCPCS lists for AR TAVR. When a note documents both stenosis and insufficiency, make sure it also states which lesion the valve was placed to treat, because the AS NCD covers TAVR for severe AS and AR falls outside it. Confirm the descriptor in the ICD-10 Encoder before the claim goes out.

What to do before October 10

If your organization wants a say in national AR coverage, the comment window is this week. After it closes, the next formal step is the proposed decision memo due March 10, 2027.

For claims in the meantime, treat AR TAVR as a MAC question. Check whether your MAC has published a coverage position for TAVR in aortic regurgitation, and when a case runs in a clinical trial or IDE study, keep the study documentation with the claim. Use the Evidence Builder to line up the heart-team evaluation and operative note so the indication is clear on review.