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Sep 1, 2026
Washington, DC — On August 31, the CardioVascular Coalition (CVC) submitted a comment letter to Centers for Medicare & Medicaid Services (CMS) on the CY 2027 Hospital Outpatient / Ambulatory Surgical Center Prospective Payment System Proposed Rule. In its letter, CVC, whose members include providers and industry representing physicians and staff in 45 states at more than 378 centers where minimally invasive cardiovascular care is delivered, calls on CMS to protect payment continuity for lower extremity revascularization and to support timely patient access to innovative technologies for peripheral artery disease (PAD).
The letter addresses four issues: complexity adjustments for the new Lower Extremity Revascularization (LER) code set, the annual ASC payment update, and transitional pass-through payment status for two devices used to treat complex PAD, the Esprit™ BTK Everolimus Eluting Resorbable Scaffold System and the Santreva™-ATK Endovascular Revascularization Catheter.
READ THE COMMENT LETTER
CVC CY 2027 OPPS / ASC Proposed Rule Comment Letter (CMS-1850-P) • .pdf
The letter states, in part, “A change in coding structure should not, by itself, cause hospitals or ASCs to lose payment recognition for procedures that continue to involve comparable clinical complexity and resource use. Consistent use of predecessor-code data would help maintain continuity during the transition to the new LER code set and ensure that complexity-adjustment determinations reflect the available claims experience.”
On transitional pass-through payment, the letter goes on to say, “The CVC supports CMS's Transitional Pass-Through program because it promotes timely patient access to innovative technologies that address important unmet clinical needs.” It adds, “Successful CTO crossing is not simply a procedural step, it is often the defining factor that determines whether an endovascular procedure can be completed.”
The letter makes the following requests:
Carry forward the LER crosswalk. CVC asks CMS to apply its CY 2026 predecessor-code crosswalk to the new LER codes (CPT 37254–37299) for CY 2027, and to use that claims data to recognize qualifying code combinations for complexity adjustments under both the OPPS and ASC payment systems.
Keep the hospital market basket for ASCs. “The CVC supports CMS' continued use of the hospital market basket as the annual update mechanism for ASC payments.”
Finalize pass-through status for Esprit™ BTK. CVC encourages CMS to finalize its proposed approval, citing three-year data in which 90% of Esprit™ BTK patients with chronic limb-threatening ischemia did not require reintervention.
Reconsider pass-through status for Santreva™-ATK. CVC urges CMS to revisit its proposed denial, arguing the catheter is fundamentally different from a conventional guiding catheter and represents “a meaningful advancement in the treatment of complex femoropopliteal CTOs.”