TAVR NCD Proposal expected shortly: A review of key points that will be a positi

Research evidence excerpt

TAVR NCD Proposal expected shortly: A review of key points that will be a positi

Flash Note Health Care | Medical Supplies & Devices

May 26, 2026

Edwards Lifesciences Corp Vijay Kumar Kevin Joaquin 212-653-9033 212-446-9493

EW | $83.20 Vijay.Kumar@EvercoreISI.com kevin.joaquin@evercoreisi.com

Outperform | Target Price/Base Case: $93.00 Nicholas Whalen, CFA Daniel Markowitz

Commentary 646-225-6027 212-812-2936

Nicholas.Whalen@evercoreISI.com Daniel.Markowitz@evercoreISI.com

TAVR NCD Proposal expected shortly: A review of key points that will be a

positive for TAVR

CMS is expected to release its TAVR NCD proposal over the coming weeks. We wanted to layout out the key

requests and what we see as being positive for TAVR. Here are the details:

Background: CMS first established the TAVR NCD under CED in 2012 and updated it in 2019 as indications

expanded. CMS reviews extensive public comments from physicians and other stakeholders that help inform

proposed and final NCD updates. Below is our review of these comments

What the public comments are focused on:

• CMS expansion of TAVR coverage to asymptomatic severe AS: Public comments surround coverage

following Early TAVR and FDA approval; debate on how to cover vs. whether or not to cover it

• Coverage with Evidence Development (CED) is a point of debate: Today, CED (registry/evidence

requirements) still remains for symptomatic severe AS, the question is whether this should continue; no debate

on new indications, retain CED requirements

• Heart team & registry oversight: Comments emphasize impt of Heart Team + TVT registry

• Loosening of operational restrictions: Potential probability of looser operator rules, telehealth/flexible

evaluations, removal of requirement for dual operators and/or softer volume thresholds