CMS finalizes TAVR coverage: study requirement dropped for symptomatic AS, added for asymptomatic
On September 10, 2026, CMS finalized its TAVR national coverage decision. Symptomatic severe aortic stenosis no longer needs coverage with evidence development, asymptomatic severe AS is coverable only inside a CED study, and CMS reset the operator-volume and in-person heart-team requirements.
By the HCC Buddy Coding Team
Published September 11, 2026

Key Takeaways
- →TAVR for symptomatic severe aortic stenosis no longer requires a coverage with evidence development (CED) study; asymptomatic severe AS becomes coverable only when furnished inside one. CMS finalized both on September 10, 2026 (decision memo CAG-00430R2).
- →Symptomatic severe aortic stenosis is covered under Section 1862(a)(1)(A) of the Social Security Act, with the CED requirement removed.
- →Asymptomatic severe aortic stenosis is covered only when the TAVR procedure is furnished in the context of a CMS-approved CED study, under Section 1862(a)(1)(E).
- →A TAVR operator must perform at least 20 transcatheter cardiac valve procedures a year (15 of them TAVR), or 40 over two years (30 TAVR); CMS set the volume requirement at the operator level.
- →The pre-procedure heart-team evaluation must be in person and cannot be satisfied through a virtual encounter, and the heart team must include at least one cardiac surgeon and one interventional cardiologist with hospital privileges.
Two things changed for TAVR claims on September 10, 2026. Symptomatic severe aortic stenosis no longer needs a coverage with evidence development (CED) study, and asymptomatic severe aortic stenosis is now coverable, but only when the procedure is furnished inside a CMS-approved CED study. CMS finalized both in its transcatheter aortic valve replacement (TAVR) decision memo, CAG-00430R2.
What CMS finalized
CMS made three changes at once. It dropped the CED requirement for symptomatic severe aortic stenosis. It extended coverage to asymptomatic severe AS under CED. And it revised the criteria for pre-procedure patient assessment, intraoperative care, and operator and hospital procedural volume.
The procedure is covered only when it uses a complete aortic valve and implantation system that holds FDA premarket approval (PMA) for that system's approved indication.
Symptomatic severe AS: the study requirement is gone
For symptomatic severe aortic stenosis, coverage now sits under Section 1862(a)(1)(A) of the Social Security Act, with no CED condition attached. That drops the study strings the prior NCD tied to these cases.
Practical read: the coverage basis for a symptomatic TAVR claim changed, but don't assume the billing mechanics did. CMS will revise the TAVR national coverage determination through the manual language in Appendix A of the memo, and the billing instructions follow through that implementation. Wait for it before you touch a modifier or a condition code.
Asymptomatic severe AS: covered, but only inside a CED study
This is the expansion. TAVR for asymptomatic severe aortic stenosis is now covered, but under CED and Section 1862(a)(1)(E). In plain terms, the claim only holds if the procedure is furnished in the context of a CMS-approved CED study. Coverage for asymptomatic disease is conditional on that, not automatic.
CMS also opened a separate national coverage analysis the same day for TAVR in aortic regurgitation (CAG-00430R3). That's a different question and isn't decided here.
New operator volume and heart-team rules
CMS finalized operator-level volume requirements for TAVR. A TAVR operator must be an interventional cardiologist or cardiac surgeon on the heart team and must perform:
- at least 20 total transcatheter cardiac valve procedures a year, at least 15 of them TAVR; or
- at least 40 such procedures over two years, at least 30 of them TAVR.
The heart team must include at least one cardiac surgeon and one interventional cardiologist experienced in aortic valve disease, each with clinical privileges at the hospital where the TAVR is furnished. The pre-procedure evaluation has to be in person: CMS states it can't be satisfied through a virtual encounter. A telehealth-only evaluation is a coverage gap.
Old vs new: TAVR coverage at a glance
| Coverage element | Under the 2019 NCD | Under the Sept 10, 2026 final decision |
|---|---|---|
| Symptomatic severe AS | Covered, with CED | Covered, CED requirement removed |
| Asymptomatic severe AS | Not covered | Covered when furnished under CED |
| Volume requirement | Hospital and operator thresholds | Operator-level: 20+ valve procedures/yr (15+ TAVR) or 40+/2 yr (30+ TAVR) |
| Heart-team evaluation | Required | Required, and must be in person |
What this changes on the claim
For a facility or cardiology coder, the split is the thing to hold onto. Symptomatic severe AS drops a condition. Asymptomatic severe AS gains one. The diagnosis on the record decides which coverage path the claim rides, so the assessment that establishes symptoms, or their absence, has to be legible in the note. Confirm the aortic stenosis diagnosis maps cleanly in the encoder, and pull the supporting documentation together with the evidence builder so the heart-team evaluation and operative note back the coverage path you billed. For the descriptors themselves, the code book carries the current aortic stenosis entries (I35.0, or I35.2 when insufficiency coexists). It's the second CMS coverage decision to cross the desk in recent months, alongside the ColoSense NCD, and both turn on the same discipline: match the claim to what the record actually shows.
What coders should do now
- 1For symptomatic severe AS TAVR claims, drop the CED/study condition CMS just removed. Coverage now rests on the FDA-approved device and the Section 1862(a)(1)(A) criteria. Hold your billing mechanics steady until CMS implements the updated NCD.
- 2For asymptomatic severe AS, treat coverage as conditional. The claim only holds if the procedure is furnished under a CMS-approved CED study, so confirm the case is running under one before it bills.
- 3Check the record shows the operator meets the new volume threshold and that the heart team included a cardiac surgeon and an interventional cardiologist with privileges at the hospital.
- 4Confirm the pre-procedure heart-team evaluation was in person. CMS made explicit that a virtual encounter doesn't satisfy it, so a telehealth-only evaluation is a coverage gap.
- 5Reconcile the aortic stenosis diagnosis (I35.0, or I35.2 when insufficiency coexists) with the coverage path, since symptomatic and asymptomatic disease now bill under different sections of the Act.
Frequently Asked Questions
Does Medicare still require coverage with evidence development for TAVR in symptomatic severe aortic stenosis?
No. In the final decision memo posted September 10, 2026, CMS removed the CED requirement for TAVR in symptomatic severe aortic stenosis. Coverage falls under Section 1862(a)(1)(A) of the Social Security Act when the FDA-approved device and the heart-team, operator, and hospital conditions are met.
Is TAVR now covered for asymptomatic aortic stenosis?
Yes, but only under coverage with evidence development. CMS expanded TAVR coverage to asymptomatic severe aortic stenosis under Section 1862(a)(1)(E), which means the procedure must be furnished in the context of a CMS-approved CED study to be covered.
What are the new TAVR operator volume requirements?
A TAVR operator must perform at least 20 total transcatheter cardiac valve procedures each year, at least 15 of which are TAVR, or at least 40 over two years with at least 30 TAVR. CMS set the requirement at the operator level rather than the hospital level.
Can the heart-team evaluation for TAVR be done by telehealth?
No. The final decision memo states that the in-person evaluation by a heart team TAVR operator cannot be satisfied through a virtual encounter.
When does the new TAVR coverage take effect?
CMS posted the final decision memo on September 10, 2026. It does not name a separate effective date. CMS will revise the TAVR national coverage determination through the manual language in Appendix A of the memo, and billing instructions follow through that implementation.
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HCC Buddy Coding Team
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