Medicare National Coverage Determinations (NCD) Manual (Pub. 100-03), Ch. 1 § 20.33
Transcatheter Edge-to-Edge Repair (TEER) for Mitral Valve
20.33 - Transcatheter Edge-to-Edge Repair (TEER) for Mitral Valve
Regurgitation
(Rev. 12112; Issued: 06-29-23; Effective: 07- 31-23; Implementation: 07-31- 23)
A. General
Transcatheter Edge-to-Edge Repair (TEER) of the mitral valve is used in the treatment of
mitral regurgitation. TEER approximates the anterior and posterior mitral valve leaflets
by grasping them with a clipping device in an approach similar to a treatment developed
in cardiac surgery called the Alfieri stitch.
B. Nationally Covered Indications
The Centers for Medicare & Medicaid Services (CMS) covers TEER of the mitral valve
under Coverage with Evidence Development (CED) with the following conditions:
A. For the treatment of symptomatic moderate-to-severe or severe functional mitral
regurgitation (MR) when the patient remains symptomatic despite stable doses of
maximally tolerated guideline-directed medical therapy (GDMT) plus cardiac
resynchronization therapy, if appropriate, or for the treatment of significant
symptomatic degenerative MR when furnished according to a Food and Drug
Administration (FDA)-approved indication and when all of the following conditions
are met:
1. The procedure is furnished with a mitral valve TEER system that has received
FDA premarket approval (PMA).
2. The patient (preoperatively and postoperatively) is under the care of a heart team:
a cohesive, multidisciplinary, team of medical professionals. The heart team
concept embodies collaboration and dedication across medical specialties to offer
optimal patient-centered care. The heart team must include the following
members with experience and training as specified:
a. Cardiac surgeon
i. With ≥ 20 mitral valve surgeries per year or ≥ 40 over two years,
50% of which are mitral valve repairs; and,
ii. Who is board eligible or certified in cardiothoracic surgery or
similar foreign equivalent.
b. Interventional cardiologist
i. With professional experience of ≥ 50 career structural heart disease
procedures; or ≥ 30 left-sided structural procedures per year; and,
ii. With participation in ≥ 20 career trans-septal interventions
including 10 as primary or co-primary operator; and,
iii. Who is board eligible or certified in interventional cardiology or
similar foreign equivalent.
c. Interventional echocardiographer (cardiologist or anesthesiologist)
i. With professional experience of ≥ 10 trans-septal guidance
procedures and ≥ 30 structural heart procedures; and,
ii. Who is board eligible or certified in transesophageal
echocardiography with advanced training as required for
privileging by the hospital where the TEER is performed.
d. Heart failure cardiologist experienced in treating patients with advanced
heart failure (only required for functional MR patients); and,
e. Providers from other physician groups as well as advanced patient
practitioners, nurses, research personnel, and administrators.
3. Each patient’s suitability for surgical mitral valve repair, TEER, or palliative
therapy must be evaluated, documented, and made available to other heart team
members. Additionally, for patients with functional MR, the heart team heart
failure cardiologist must document that the patient has persistent symptoms
despite maximally tolerated GDMT and cardiac resynchronization therapy, if
appropriate, as described below:
a. For patients with functional MR: the heart team interventional cardiologist
and heart team heart failure cardiologist independently evaluate the patient
using information in the medical record and a face-to-face examination.
To decrease patient burden, the heart team heart failure cardiologist may
meet this requirement through a review of the patient’s records and images
if the patient has an established relationship with a cardiologist
experienced in treating patients with advanced heart failure.
b. For patients with degenerative MR: the heart team interventional
cardiologist and heart team cardiac surgeon must independently evaluate
the patient using information in the medical record and a face-to-face
examination.
4. An interventional cardiologist or cardiac surgeon from the heart team must
perform the mitral valve TEER and an interventional echocardiographer from the
heart team must perform transesophageal echocardiography during the procedure.
The interventional echocardiographer may not also furnish anesthesiology during
the same procedure. The interventional cardiologist and cardiac surgeon may
jointly participate in the intra-operative technical aspects of TEER as appropriate.
All physicians who participate in the procedure must have device-specific training
as required by the manufacturer.
5. Mitral valve TEERs must be furnished in a hospital with appropriate
infrastructure and experience that includes, but is not limited to:
a. On-site heart valve surgery and interventional cardiology programs;
b. Post-procedure intensive care facility with personnel experienced in
managing patients who have undergone open-heart procedures;
c. Hospital volume requirements below must be met and maintained:
i. ≥ 20 mitral valve surgical procedures for severe MR per year or ≥
40 over two years, of which at least 10 (or 20 over two years) must
be mitral valve repairs; and,
ii. ≥ 2 physicians with cardiac surgery privileges experienced in
valvular surgery; and,
iii. ≥ 1 physician with interventional cardiology privileges; and,
iv. ≥ 300 percutaneous coronary interventions (PCIs) per year.
6. The heart team and hospital are participating in a prospective, national, audited
registry that: 1) comprehensively enrolls TEER patients; 2) accepts all
manufactured devices; 3) follows the patient for at least one year; and, 4)
complies with relevant regulations relating to protecting human research subjects,
including 45 Code of Federal Regulations (CFR) Part 46 and 21 CFR Parts 50 &
56.
The following outcomes must be tracked by the registry, and the registry must be
designed to permit identification and analysis of patient, practitioner, and facility
level variables that predict each of these outcomes:
a. Stroke;
b. All-cause mortality;
c. Repeat TEER or other mitral procedures;
d. Transient Ischemic Attacks (TIAs);
e. Major vascular events;
f. Renal complications;
g. Functional capacity; and
h. Quality of Life (QoL).
7. The registry shall collect all data necessary and have a written executable analysis
plan in place to address the following questions. Specifically, for the CED
question d, this must be addressed through a composite metric. For the below
CED questions (a-e), the results must be reported publicly as described in CED
criterion k.
a. When TEER procedures are performed outside a controlled clinical study,
how do outcomes and adverse events compare to the pivotal clinical
studies?
b. How do outcomes and adverse events in subpopulations compare to
patients in the pivotal clinical studies?
c. What is the long-term (≥ 5 year) durability of the device?
d. What are the long-term (≥ 5 year) outcomes and adverse events?
e. How do the demographics of registry patients compare to the pivotal
studies?
Consistent with section 1142 of the Act, the Agency for Healthcare Research and
Quality (AHRQ) supports clinical research studies that CMS determines meet the
above-listed standards and address the above-listed research questions.
B. Mitral valve TEERs are covered for uses that are not expressly listed as an FDA-
approved indication when performed within a clinical study that fulfills all of the
following:
1. An interventional cardiologist or cardiac surgeon must perform the mitral valve
TEER and an interventional echocardiographer must perform transesophageal
echocardiography during the procedure. The interventional echocardiographer
may not also furnish anesthesiology during the same procedure. The
interventional cardiologist and cardiac surgeon may jointly participate in the intra-
operative technical aspects of TEER as appropriate. All physicians who
participate in the procedure must have device specific training as required by the
manufacturer.
2. As a fully-described, written part of its protocol, the clinical research trial must
critically evaluate the following questions at 12 months or longer follow-up:
a. What is the rate of all-cause mortality in the intervention group?
b. What is the rate of re-operations (open surgical or transcatheter) of the
mitral valve in the intervention group?
c. What is the rate of moderate-to-severe or severe MR in the intervention
groups?
3. As a fully-described, written part of its protocol, the clinical research study must
critically evaluate not only each patient’s quality of life pre- and post-TEER
(minimum 1 year), but must also address at least one of the following questions:
a. What is the incidence of stroke?
b. What is the incidence of TIAs?
c. What is the incidence of major vascular events?
d. What is the incidence of renal complications?
e. What is the incidence of worsening MR?
f. What is the change in quality of life after TEER?
g. What is the change in the patient’s functional capacity after TEER?
4. The clinical study must adhere to the following standards of scientific integrity
and relevance to the Medicare population:
a.
The principal purpose of the study is to test whether the item or service
meaningfully improves health outcomes of affected beneficiaries who are
represented by the enrolled subjects.
b.
The rationale for the study is well supported by available scientific and
medical evidence.
c.
The study results are not anticipated to unjustifiably duplicate existing
knowledge.
d.
The study design is methodologically appropriate and the anticipated
number of enrolled subjects is sufficient to answer the research question(s)
being asked in the National Coverage Determination (NCD).
e.
The study is sponsored by an organization or individual capable of
completing it successfully.
f.
The research study is in compliance with all applicable Federal regulations
concerning the protection of human subjects found in the Code of Federal
Regulations (CFR) at 45 CFR Part 46. If a study is regulated by the Food
and Drug Administration (FDA), it is also in compliance with 21 CFR
Parts 50 and 56. In addition, to further enhance the protection of human
subjects in studies conducted under CED, the study must provide and
obtain meaningful informed consent from patients regarding the risks
associated with the study items and /or services, and the use and eventual
disposition of the collected data.
g.
All aspects of the research study are conducted according to appropriate
standards of scientific integrity.
h.
The study has a written protocol that clearly demonstrates adherence to the
standards listed here as Medicare requirements.
i.
The study is not designed to exclusively test toxicity or disease
pathophysiology in healthy individuals. Such studies may meet this
requirement only if the disease or condition being studied is life
threatening as defined in 21 CFR §312.81(a) and the patient has no other
viable treatment options.
j.
The clinical research studies and registries are registered on the
www.ClinicalTrials.gov website by the principal sponsor/investigator
prior to the enrollment of the first study subject. Registries are also
registered in the Agency for Healthcare Quality (AHRQ) Registry of
Patient Registries (RoPR).
k.
The research study protocol specifies the method and timing of public
release of all prespecified outcomes to be measured including release of
outcomes if outcomes are negative or study is terminated early. The results
must be made public within 12 months of the study’s primary completion
date, which is the date the final subject had final data collection for the
primary endpoint, even if the trial does not achieve its primary aim. The
results must include number started/completed, summary results for
primary and secondary outcome measures, statistical analyses, and adverse
events. Final results must be reported in a publicly accessibly manner;
either in a peer-reviewed scientific journal (in print or on-line), in an on-
line publicly accessible registry dedicated to the dissemination of clinical
trial information such as ClinicalTrials.gov, or in journals willing to
publish in abbreviated format (e.g., for studies with negative or incomplete
results).
l.
The study protocol must explicitly discuss beneficiary subpopulations
affected by the item or service under investigation, particularly
traditionally underrepresented groups in clinical studies, how the inclusion
and exclusion criteria effect enrollment of these populations, and a plan
for the retention and reporting of said populations on the trial. If the
inclusion and exclusion criteria are expected to have a negative effect on
the recruitment or retention of underrepresented populations, the protocol
must discuss why these criteria are necessary.
m.
The study protocol explicitly discusses how the results are or are not
expected to be generalizable to affected beneficiary subpopulations.
Separate discussions in the protocol may be necessary for populations
eligible for Medicare due to age, disability or Medicaid eligibility.
Consistent with section 1142 of the Act, the Agency for Healthcare Research and
Quality (AHRQ) supports clinical research studies that meet the above-listed
standards and address the above-listed research questions.
The principal investigator must submit the complete study protocol, identify the
relevant CMS research question(s) that will be addressed, and cite the location of
the detailed analysis plan for those questions in the protocol, plus provide a
statement addressing how the study satisfies each of the standards of scientific
integrity (a. through m. listed above), as well as the investigator's contact
information, to the address below. The information will be reviewed, and
approved studies will be identified on the CMS Website.
Director, Coverage and Analysis Group
Re: TEER CED
Centers for Medicare & Medicaid Services (CMS)
7500 Security Blvd., Mail Stop S3-02-01
Baltimore, MD 21244-1850
Email address for protocol submissions: clinicalstudynotification@cms.hhs.gov
Email subject line: "CED TEER [name of sponsor/primary investigator]"
C. Nationally Non-Covered Indications
TEER of the mitral valve is not covered under the following circumstances:
1. For patients in whom existing co-morbidities would preclude the expected benefit
from a mitral valve TEER procedure.
2. In patients with untreated severe aortic stenosis.
D. Other
CMS will consider published, peer-reviewed evidence periodically, following the
effective date of this NCD and reconsider the policy when appropriate. The NCD will
expire 10 years from the effective date if it is not reconsidered during that time. Upon
expiration, coverage will be at the discretion of the Medicare Administrative Contractors.