CPT code 33361 – Transcatheter aortic valve replacement (transfemoral)

Key takeaways

CPT Code 33361 is TAVR through a percutaneous femoral artery approach only. Each access site in the 33361-33366 family has its own code, and they are not interchangeable.

CMS assigns 33361 a 000-day global period, so post-operative visits after the procedure day are not bundled into the surgical payment.

CMS NCD 20.32 governs Medicare coverage, and claims without a documented heart team decision are routinely denied.

Practice management software like Pabau tracks prior authorization status and flags missing documentation before TAVR claims are submitted.

CPT Code 33361: Official descriptor and procedure overview

CPT Code 33361 is defined by the American Medical Association as: Transcatheter aortic valve replacement (TAVR/TAVI) with prosthetic valve; percutaneous femoral artery approach.

That single qualifier, “percutaneous femoral artery approach,” is what separates 33361 from the rest of the TAVR family. If the operative report documents any other access site, a different code applies.

TAVR replaces a diseased aortic valve without open-chest surgery. A multidisciplinary heart team performs the procedure, typically an interventional cardiologist and a cardiac surgeon working together. The setting is a hybrid operating room or catheterization laboratory. The transfemoral route is the most common approach because it is the least invasive and carries the lowest complication profile in appropriate candidates.

What the code includes (and what it does not)

Code 33361 is a comprehensive procedure code. It bundles the catheter insertion, valve positioning, deployment, and post-deployment imaging assessment performed in the same operative session. It does not include separate diagnostic cardiac catheterization, pre-operative echocardiography, or temporary pacemaker insertion when billed as a standalone service on a different date.

• Included in 33361: valve delivery, balloon valvuloplasty when performed, fluoroscopic guidance, and post-deployment aortography
• Not separately billable on the same date: diagnostic left heart catheterization (93452/93453) when performed for valve sizing
• Separately billable with documentation: temporary transvenous pacemaker (33210) when clinically distinct from the primary procedure

CPT Code 33361 vs. 33362-33366: Choosing the correct TAVR approach code

The TAVR CPT code family maps one-to-one with surgical approach. Selecting the correct code is a documentation-first decision: read the operative report, identify the access site, then match it to the code below. Billing 33361 when the operative note documents a transapical incision misrepresents the service rendered, and auditors treat it as exactly that.

Transfemoral access now accounts for about 95–96% of TAVR procedures in the United States, according to STS/ACC TVT Registry data. The split that matters most is percutaneous versus open. A femoral artery reached through a surgical cutdown is 33362, not 33361.

When a patient’s iliofemoral anatomy prevents femoral access, the surgeon documents the alternative approach explicitly, and the coder selects the corresponding code. Choosing 33361 by default when the approach is ambiguous is the fastest route to a retrospective audit finding.

The decision below runs the same check a coder makes on every TAVR operative note, starting from the documented access site.

CPT 33361 vs. open aortic valve replacement codes (33405/33406)

Open surgical aortic valve replacement uses different CPT codes entirely. Confusing the transcatheter and open-surgery families is a common source of claim errors, particularly when a planned TAVR converts to open surgery intraoperatively.

When a TAVR procedure converts to open surgery, bill the open-surgery code (33405 or 33406) that reflects the procedure performed. Do not report 33361 alongside an open AVR code for the same operative session.

ICD-10 diagnosis codes that support CPT 33361

Medical necessity for TAVR hinges on documented aortic valve pathology. Nonrheumatic aortic stenosis drives the overwhelming majority of 33361 claims, and its ICD-10-CM code is I35.0. Payers cross-reference the diagnosis code against their coverage policy for TAVR. An unspecified valve disorder code, used when a more specific one exists, is a straightforward denial trigger.

According to the CMS ICD-10-CM coding guidelines, I35.2 is the correct code when both stenosis and insufficiency are documented. Do not report I35.0 and I35.1 separately.

Documentation requirements for CPT Code 33361

Payers and auditors look for three answers in every TAVR operative report. They check what condition was treated, what approach was used, and who made the clinical decision. Missing any of these three elements is sufficient grounds for denial, regardless of whether the procedure itself was medically appropriate.

• Approach specificity: the operative note must state “percutaneous transfemoral” or “femoral artery access” explicitly. General statements such as “transcatheter approach” without naming the site do not support 33361 over 33362 through 33366
• Valve type and device: document the prosthetic valve manufacturer and model (e.g. Edwards SAPIEN or Medtronic Evolut). Some payer policies (UHC, BCBS) require the device to be FDA-approved for the indication
• Heart team documentation: CMS NCD 20.32 requires evidence of a multidisciplinary heart team assessment. The medical record must contain a note from both the interventional cardiologist and the cardiac surgeon confirming joint decision-making
• STS risk score: document the Society of Thoracic Surgeons Predicted Risk of Mortality (STS-PROM) score. While CMS no longer mandates a specific score threshold for all indications, many commercial payers still reference it in their coverage criteria
• Echocardiographic findings: pre-procedural transthoracic or transesophageal echocardiogram documenting valve area, gradient, and ejection fraction supports the medical necessity determination
• Site of service accuracy: TAVR is an inpatient or hospital outpatient procedure. Billing under a physician office POS code (11) will result in claim rejection

For high-complexity cardiac codes, build a documentation checklist into the pre-submission workflow. Each chart then gets checked against these six points before the claim leaves the practice.

Prior authorization requirements for CPT 33361

Prior authorization for TAVR is required by most commercial payers, though requirements vary. Medicare itself does not require prior authorization for TAVR under traditional fee-for-service, but Medicare Advantage plans may impose their own pre-auth rules. Verifying insurance eligibility before scheduling is the first step in preventing authorization-related denials.

Payer-specific prior authorization landscape

Payer policies for transcatheter heart valve procedures change periodically as FDA indications expand (TAVR was approved for low-surgical-risk patients in 2019). Verify current authorization requirements directly with each payer before each case rather than relying on prior approval experience from 12 or more months ago.

Medicare reimbursement for CPT 33361

Medicare pays for CPT 33361 through two separate channels. The Medicare Physician Fee Schedule (MPFS) covers the professional (physician) component. The Inpatient or Outpatient Prospective Payment System (IPPS or OPPS) covers the facility component.

Professional fee (MPFS)

The professional reimbursement for 33361 is based on Relative Value Units (RVUs) published in the annual CMS Physician Fee Schedule. Rates change each January 1. The work RVU for 33361 is substantially higher than routine cardiology procedures, reflecting the complexity and time involved.

Geographic adjustment (GPCI) applies. A cardiac surgeon in a high-cost metro area is paid more for the same code than one in a rural market. Before claims go out, the superbill has to carry the correct provider taxonomy, NPI, and place of service.

Facility fee (inpatient vs. outpatient)

Inpatient TAVR is grouped into a Medicare Severity Diagnosis Related Group (MS-DRG). The DRG assignment depends on whether a major cardiovascular complication or comorbidity (MCC) is present. Outpatient TAVR (when performed in a hospital outpatient department) is reimbursed under the OPPS Ambulatory Payment Classification (APC) system.

Professional services go out on an 837P claim, while the facility bills on the UB-04 (837I). The electronic remittance advice (ERA/835) shows the DRG or APC assignment used to calculate payment.

Modifiers applicable to CPT Code 33361

Modifier selection for 33361 follows standard CMS rules for a procedure with a 000-day global period, plus a few TAVR-specific patterns. A wrong or missing modifier is a common reason co-surgeon claims and same-day return-to-OR claims are denied.

Modifier 62 is the standard configuration for TAVR professional billing. CMS NCD 20.32 requires the cardiac surgeon and the interventional cardiologist to perform the intraoperative technical work together. Each submits 33361-62 independently and is paid 62.5% of the fee schedule amount. Verify that both providers are enrolled with the payer first. A missing enrollment denies that provider’s claim while the other one processes normally.

Global period and post-operative care for CPT 33361

CPT Code 33361 carries a 000-day global surgery period in the CMS Physician Fee Schedule. The rest of the TAVR family, 33362 through 33366, carries the same indicator. The global package covers only the day of the procedure. No pre-operative day and no post-operative days are attached to it.

A billing reference that lists 090 for TAVR is out of date or wrong, so check the current fee schedule file. Treating 33361 as a 90-day bundle leaves every follow-up visit after the procedure day unbilled.

What is bundled with CPT 33361, and what is billed separately

• Bundled (day of the procedure only): the routine pre-procedure assessment and the immediate post-procedure care the operating physicians provide that day
• Separately billable after the procedure day: post-operative E/M visits, in hospital or in the office, subject to standard payer documentation rules. No modifier 24 is needed
• Separately billable on the same day with modifier 25: a significant, separately identifiable E/M service that goes beyond the usual pre-procedure assessment
• Same-day return to the OR: modifier 78 for a related complication, or modifier 79 for an unrelated procedure. Procedures on later days are billed without either modifier
• Critical care (99291, 99292): separately billable when documented as unrelated to the procedure. Medicare asks for modifier FT when that critical care falls on the day of the TAVR

Follow-up echocardiography is reported with its own imaging code rather than folded into the TAVR payment. Each co-surgeon billing under modifier 62 reports their own post-operative visits with the E/M code that fits the service. Commercial plans can still set their own rules, so confirm how each payer treats follow-up after structural heart procedures.

Common denial reasons for CPT 33361 claims

TAVR claims are denied more often than most surgical procedure codes. The main reason is that their documentation requirements go well beyond those for routine cardiology services. The most effective denial prevention happens before submission, with a checklist run against each operative report. Tracking denial reason codes by category helps billing teams identify which step in the workflow is producing the most rejections.

• Wrong approach code selected (most common): 33361 was billed when the operative report documents a transapical or transaortic approach. Read the operative note before selecting the code, every time
• Missing prior authorization: commercial payers that require pre-auth will deny the claim outright. The denial typically arrives with remark code CO-197 (pre-certification absent)
• Insufficient medical necessity documentation: the record lacks a heart team note from both the cardiologist and the cardiac surgeon. Missing echocardiographic data on severe aortic stenosis triggers the same denial
• STS score not documented: some commercial payers and Medicare Advantage plans still require a documented STS-PROM score. CMS FFS NCD 20.32 no longer mandates a minimum threshold for all patient risk tiers
• Site of service mismatch: the place of service code on the professional claim does not match the facility type where the procedure was performed
• Unbundling errors: billing diagnostic catheterization or balloon valvuloplasty as separate services when they are integral to the TAVR procedure and bundled under 33361
• CMS registry non-participation: CMS NCD 20.32 conditions Medicare coverage on the facility participating in a CMS-approved national TAVR registry. A non-participating facility cannot bill Medicare for TAVR

A denial management workflow for TAVR should route every denial into a structured appeal pathway with a 30-day turnaround target. A medical necessity appeal for 33361 should attach the operative report, the heart team note, and pre-procedural imaging. Add the payer’s own coverage policy as an exhibit. Getting a clean claim out the first time is still faster than winning a well-constructed appeal.

Payer coverage policies for TAVR (CPT 33361)

Medicare’s coverage of TAVR is governed by CMS NCD 20.32, which sets the patient eligibility criteria, operator qualifications, and facility requirements for Medicare coverage. Commercial payers generally model their policies on NCD 20.32 but may add stricter criteria.

CMS NCD 20.32 key requirements

• Heart team: procedure must be evaluated and performed by a multidisciplinary heart team including both a cardiac surgeon and an interventional cardiologist
• Operator volume: each operator (cardiologist and surgeon) must meet minimum procedural volume requirements. CMS periodically updates these thresholds
• Facility requirements: the facility must be an experienced cardiac surgical center with specific structural heart disease program infrastructure
• Registry participation: the facility must participate in a CMS-approved national TAVR data registry
• Expanded indications: CMS has progressively expanded coverage from high-risk patients (original 2012 NCD) through intermediate-risk and, following FDA approval, lower-risk surgical candidates. Confirm the current NCD version before relying on older policy summaries

Commercial payers including UnitedHealthcare and BCBS plans generally align with NCD 20.32 criteria. Some add their own requirements, such as approved device models, limits on valve designs, or an independent cardiologist review. Geisinger and similar regional payers publish transcatheter heart valve procedure policies that should be reviewed annually.

How claims management software prevents CPT 33361 denials

Many 33361 denials start with a claim assembled by hand. The coder reads the operative report in one system, checks the payer’s prior authorization in another, and keys the claim in a third. An undocumented access site or a missing heart team note slips through that handoff.

Practice management software like Pabau keeps the note, the codes, and the claim in one place. Its claims management software tracks authorization status and flags missing documentation before the claim leaves the practice. Clean claims then go out as 837 files through Pabau’s Claim.MD clearinghouse integration.

Payments come back as electronic remittance advice, so your team can check each co-surgeon payment against the expected 62.5% share. Denials are tracked by reason, which shows whether the fix belongs in the operative note template or in the authorization workflow.

Streamline TAVR billing from prior auth to ERA posting

Pabau tracks authorization status, flags missing documentation, and connects to Claim.MD for electronic submission on complex cardiology codes like CPT 33361.

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Conclusion

A 33361 claim stands or falls on one line of the operative report: percutaneous femoral artery access. When that line is explicit, the code holds up under audit. When the note says only “transcatheter,” the claim is exposed to five other codes in the same family.

Correct the global period assumption next. With a 000-day global period, post-operative visits after the procedure day are billable work. A practice still treating them as a 90-day bundle leaves payment uncollected on every TAVR case.

The trade-off is a few extra fields in the operative note template and a quarterly E/M audit. Set against a denied co-surgeon claim or a month of unbilled follow-up, both pay for themselves.

Book a demo to see how Pabau tracks prior authorization and flags missing TAVR documentation before your cardiology claims go out.

Continue your research

Need help tracking denial reason codes across payers? Denial management in healthcare covers how to categorize, track, and appeal claim denials systematically.

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Need a pre-submission review process for complex procedures? Billing compliance standards outlines the pre-submission review process that reduces first-pass denial rates.

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Want fewer TAVR claims bounced on first submission? Clean claims in medical billing sets out what a payer needs to accept a claim the first time.

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