Friday, July 11, 2025

CMS Publishes Draft NCD on Renal Denervation for Uncontrolled Hypertension

Last winter, CMS announced it would produce a National Coverage Determination on renal denervation for uncontrolled hypertension.   CMS has now issued a draft position with elaborate CED rules.  After 30 days public comment, a final decision is expected in October 2025.  This policy is worth noting as a major new CMS decision under the current administration.  CMS notes that this NCD is an example of its "Transitional Coverage for Emerging Technologies" or TCET pilot program for CED NCDs.  (CED guidance was last updated in August 2024.)

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Read the Proposal

Vascular News has a good review of the area and activities up through January 14, 2025 - here.  

  • Find the CMS tracking sheet here.   
  • Read the 12-page PDF of the Medtronic coverage request, dated December 12, 2024, here.  
  • Proposal here.

When it opened the tracking sheet, CMS wrote, 

This NCA will focus on the clinical indications for use of RDN among Medicare beneficiaries. This NCA will analyze clinical evidence for characteristics or comorbidities that make patients more or less likely to benefit from RDN and whether specific treatment conditions are necessary to achieve the outcomes demonstrated in clinical studies. Outcomes of interest may include office blood pressure, ambulatory blood pressure, nephroprotection, stroke, heart failure, decreased mortality, decreased emergency room or hospital admissions, and quality of life. The scope of this NCA is limited to radiofrequency- and ultrasound-based renal denervation procedures.

FDA & CMS History

Per Vascular News, both Medtronic and Recor Medical got FDA approval in November 2023 (for a contemporary 2023 news article here.)  For the August 2023 FDA Ad Comm - here.  See "FDA Criteria" further below.

This area of research goes back many years.   For example, there was a CMS technology assessment as far back as 2016 (!) - here.  (Reviewing 83 studies of which 9 were RCTs, in 2016 and earlier).  That 2016 review, by the Johns Hopkins Evidence Based Practice Center on an AHRQ contract, concluded there may have been "...overestimating the effect of renal denervation due to white coat effect, observation bias, and placebo effect. Data were scant on clinical endpoints, such as stroke, myocardial infarction, kidney events, hospitalization, or death. Adverse effects were uncommon but potentially serious, and included hematomas, pseudoaneurysms, and renal artery interventions." 

Pass-Through Payment

Both medical device systems got outpatient pass-through payment in November 2024 (OPPS final rule, 11-27-94).   89FR94154ff (Paradise).  89FR94164ff (Symplicity). 

At 89FR94167, CMS states the Medtronic CPT codes are 0338U/0339T, which can be assigned to APC 5192 at $5445, with a device offset of $3362, and Symplicity has a cost of $16,000.  Paradise was $23,000 (89FR94158).  After a long discussion, CMS notes it will treat Paradise and Symplicity as two categories of devices (89FR94174).

In other cases I'm aware of, FDA approval and successful CMS pass-through payment doesn't always guarantee a smooth ride with MACs.  I don't know what the experience of these two companies with MACs has been. I didn't find any draft LCDs.

The Draft NCD

The draft decision was released July 10, 2025.  The proposal is rather complex, with elaborate entry criteria and a Coverage with Evidence Development design.   

There are 7 patient criteria, 4 physician criteria, 3 facility criteria, and a number of design rules for the CED study including "active comparator."   The NCD remarks that services outside of CED are non-covered.

FDA Criteria

The CMS criteria are much more elaborate than the FDA labeling.

Intended Use.
The Symplicity G3 Renal Denervation RF Generator when used with the Symplicity Spyral multi-electrode renal denervation catheter is intended to deliver radiofrequency (RF) energy through the wall of the renal artery to denervate the kidney from sympathetic nerve hyperactivity.

Indications for use
The Symplicity Spyral Multi-Electrode Renal Denervation Catheter and the Symplicity G3 RF Generator are indicated to reduce blood pressure as an adjunctive treatment in patients with
hypertension in whom lifestyle modifications and antihypertensive medications do not adequately control blood pressure.
 
[There are also several FDA labeling contra-indications such as renal artery aneurysm, and renal artery must be in the size 3-8mm].


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AI CORNER
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I asked Chat GPT to evaluate CMS's position, as reflected in its 49-page proposal.

CMS’s stance toward the data on renal denervation (RDN) is cautiously supportive but highly conditional—best characterized as measured skepticism.

Summary of CMS’s Position:

  • Not outright skeptical: CMS acknowledges the existence of RCT evidence showing that RDN can reduce systolic blood pressure modestly in certain populations, especially in the short term. Some trials, like RADIANCE II and SPYRAL HTN-OFF MED, show statistically significant reductions in ambulatory and office BP. CMS describes these trials as having “good” methodological quality.

  • Not yet satisfied: Despite these promising results, CMS identifies several major evidence limitations—especially around:

    • Durability of effect (long-term BP control).

    • Generalizability to the Medicare population (older adults, those with comorbidities).

    • Variability of outcomes between trials (e.g., REQUIRE and RADIANCE-HTN TRIO yielded null or minimal results).

    • Subgroup uncertainty: Questions remain about which patient phenotypes benefit most (resistant vs. uncontrolled hypertension).

    • Unknown reinnervation effects and lack of reliable intra-procedural markers of successful nerve ablation.

  • Evidence Development Mandate: Accordingly, CMS is not granting unrestricted coverage, but rather placing RDN under Coverage with Evidence Development (CED). This means Medicare will pay for RDN only in CMS-approved studies, and those studies must be:

    • Longitudinal (minimum 24 months).

    • Include subgroup analysis (e.g., age, CKD stage, hypertension type).

    • Measure hard outcomes (e.g., MI, stroke, mortality), not just BP.

  • Extensive trial infrastructure required

  • CMS outlines rigorous criteria for trial design, physician qualifications, and facility infrastructure, showing its desire to control for variability and bias before expanding access.


Conclusion:

CMS's stance is not hostile, but far from fully convinced. A fair summary would be:

CMS views the current RDN data as promising but incomplete. Their tone is one of conditional optimism tempered by rigorous scientific demands. Coverage is granted only through well-controlled, long-term studies under a strict CED framework.

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Are there any particularly negative points that CMS makes, that readers should be aware of?

The most hostile or strongly skeptical viewpoint in the draft NCD appears in the evidence assessment and synthesis section, particularly when CMS discusses the clinical significance and durability of the observed blood pressure reductions.

Here’s a key example of that tone:

“The efficacy of uRDN for lowering BP was mixed…although the evidence is more varied at later time points, and the evidence is limited for durability of effect.”
— [Section III.E, Assessment of Evidence]

And even more pointedly:

“In TRIO, uRDN reduced daytime ASBP statistically, but not meaningfully… At 6 months, the per-protocol analysis indicated no significant difference… These findings are statistically different but may not be clinically meaningful.”

This wording implies that:

  • Positive short-term results may be misleading, and

  • CMS is deeply concerned about the clinical relevance of the BP reductions, even when statistically significant.

Another hostile note is struck in CMS’s review of the REQUIRE trial, which it rates as “Poor” quality and critiques harshly:

“The authors reported the possibility of patient sampling error… poor drug adherence… and no standardization of antihypertensive medications… Blinding of clinical staff was not achieved.”

[Citations confirmed by BQ]

Finally, the overall tone is implicitly hostile in the high bar CMS sets for CED studies, demanding:

  • 24-month outcomes,

  • composite endpoints including mortality and stroke,

  • subgroup analyses by CKD, age, and adherence,

  • data sharing and public reporting,

  • adherence to 17 AHRQ technical criteria.

This suggests that CMS believes the current evidence does not yet meet the evidentiary threshold needed for broad coverage, and must be rebuilt under tight federal oversight.


Summary of Most Hostile Viewpoint:

CMS casts doubt on whether the modest BP reductions seen in RDN trials are clinically meaningful or durable, especially in older adults. The tone implies skepticism about the generalizability, durability, and even the value of observed effects—strongly challenging the clinical utility of RDN in its current form.


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AHRQ Rules.
You can compare the AHRQ rules (a...m) in the Amyloid drug NCD here with the rules in the renal NCD here.  Amyloid refers to underrepresented groups at AHRQ bullet (l) [el] and the renal at AHRQ bullet (7).  

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Compare the 2016 AHRQ review and the 2025 CMS document here.