Ask Dr. Z

When TAVRs are done that do not require an incision (e.g., 33361), two interventional cardiologists do the procedure and the CVT surgeon is simply present. He states this in his dictation: "Description of Procedure: The patient was taken to the hybrid operating room and placed upon the table in the supine position. Monitoring lines and catheters were placed and then general endotracheal anesthesia formed. Details of the operative procedure will be dictated separately by the interventional cardiologists. I did not participate in the technical aspects of the procedure but was present for the entire procedure in the hybrid lab and available for any emergency or other technical assistance."

**As he never takes part in the procedure in any way can he bill as co-surgeon? When there's an incision to be made this is not an issue, he participates and his dictation reflects as much. He's been told that CMS requires him to be present even if he isn't participating so that there is still a CVT surgeon on the operating team.