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    v1.0.28
    OpenPayerPolicy UpdatesCardiologyPremera Bluecross MCOT & ILR Coverage Update | Ope…
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    CurrentPremera BluecrossPolicy 2.02.510

    Mobile Cardiac Outpatient Telemetry and Implantable Loop Recorders

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    Defines medical necessity criteria for ILR implantation and use of MCOT for outpatient cardiac rhythm monitoring, site-of-service guidance for ILR implantation, documentation requirements, coding references, and evidence summary. This part covers indications, required prior monitoring, exclusions, and related coding/evidence.

    OpenPayer is powered by Trek Health's payer performance platform. Trek continuously ingests, validates, and normalizes Transparency in Coverage data alongside payer policies and other commercial payer data to create a structured payer intelligence foundation. OpenPayer uses this foundation to deliver personalized search results, dynamically generated policy pages, and tailored policy monitoring based on each user's payers, specialties, billing codes, and areas of interest. The same intelligence powers broader payer performance workflows, including reimbursement benchmarking, contract evaluation, payer negotiations, and financial decision-making.

    Policy Summary
    PayerPremera Bluecross
    PolicyMobile Cardiac Outpatient Telemetry and Implantable Loop Recorders
    Policy CodePolicy 2.02.510
    Change TypeRevised / Added criteria (ILR addedcoding updates)
    Effective DateAug 7, 2026
    Last ReviewJun 1, 2026
    Next Review DateN/A
    Key ActionDocument prior >=14-day non-diagnostic ambulatory monitoring and relevant symptoms or cryptogenic stroke workup in office visit notes to support medical necessity for ILR/MCOT.
    SourceLink
    POLICY UPDATE CHANGES

    Policy revised effective Aug. 7, 2026; updated site-of-service and medical necessity criteria for ILR and MCOT.

    Title changed to Mobile Cardiac Telemetry and Implantable Loop Recorders; ILRs added as medically necessary when criteria are met.

    Additional ILR policy criterion added requiring prior non-diagnostic or inconclusive ambulatory cardiac monitoring of at least 14 continuous days.

    Expanded not medically necessary policy statement to include ILRs and monitoring of asymptomatic individuals.

    Minor edits clarifying site of service review applies only to ILRs and does not apply to IHS facilities.

    Added implantable loop recorders as medically necessary when criteria are met.

    Added criterion requiring prior non-diagnostic or inconclusive ambulatory cardiac monitoring of at least 14 continuous days before ILR.

    Expanded not medically necessary statement to include ILRs and monitoring of asymptomatic individuals.

    Title changed to Mobile Cardiac Telemetry and Implantable Loop Recorders.

    Minor edits to clarify site of service review is only for ILR and minor clarity edits to ILR criteria.

    2Covered technologies (ILR, MCOT)
    >=14dRequired prior monitoring duration (ILR)
    48hSymptom frequency cutoff for MCOT
    1%Potentially emergent events detected (study)
    33285,C1764,E0616Added codes (CPT/HCPCS)

    Coverage Summary

    This policy covers medical necessity criteria for outpatient cardiac rhythm monitoring using Implantable Loop Recorders (ILR) and Mobile Cardiac Outpatient Telemetry (MCOT), and includes site-of-service guidance, documentation and coding requirements. Effective date: Aug. 7, 2026; last review: Jun. 1, 2026.

    Key thresholds in the policy include a required prior non-diagnostic or inconclusive ambulatory cardiac monitoring period of >= 14 continuous days before ILR is considered, and MCOT is targeted for individuals with symptoms occurring less frequently than once every 48 hours (i.e., symptom frequency cutoff <48 hours).

    High-level covered technologies specified are ILR (implantable memory loop devices with CPT 33285 and HCPCS C1764/E0616 listed) and MCOT (external mobile telemetry with CPT 93228/93229); the scope is limited to these device classes.

    Quick Thresholds
    Prior ambulatory monitoring duration (ILR)>= 14 continuous days
    Prior ambulatory monitoring duration (MCOT prerequisite)>= 14 continuous days (external ambulatory cardiac event monitoring non-diagnostic)
    Symptom frequency threshold for MCOTSymptoms occurring less frequently than once every 48 hours
    Holter/telemetry requirement for cryptogenic stroke workupNegative 24- to 48-hour Holter monitor (and/or 48-hour telemetry) prior to further extended monitoring/ILR
    MELD score site-of-service threshold> 8 (advanced liver disease may justify hospital outpatient site)
    COPD / Asthma FEV1 site-of-service thresholdsCOPD: FEV1 < 50%; Poorly controlled asthma: FEV1 < 80% despite treatment

    Implantable Loop Recorder (ILR) — Medically Necessary

    ILR (implantable loop recorder) - Medically Necessary

    Covered when ALL of the following are met:

    ALL of the following

    • AND one of

      • Prior non-diagnostic or inconclusive ambulatory cardiac monitoring of at least 14 continuous days>= 14 continuous days

        Added to ILR criteria effective Aug. 7, 2026

      • Recurrent unexplained episodes of presyncope, syncope, palpitations, or dizziness
      • Evaluation of suspected atrial fibrillation (AF) as a cause of cryptogenic stroke with completed negative standard workup for AF including 24-hour Holter monitoring24-hour Holter negative

    Mobile Cardiac Outpatient Telemetry (MCOT) — Medically Necessary

    MCOT (mobile cardiac outpatient telemetry) - Medically Necessary

    Covered when ALL of the following are met:

    ALL of the following

    • Previous external ambulatory cardiac event monitoring of at least 14 continuous days with a non-diagnostic outcome>= 14 continuous days
    • AND one of

      • Individual has symptoms of cardiac arrhythmia (recurrent palpitations, dizziness, presyncope, or syncope) occurring less frequently than once every 48 hours< = symptoms less frequent than once every 48 hours
      • Evaluation of suspected atrial fibrillation as a cause of cryptogenic stroke

    Not Medically Necessary / Expanded Exclusions

    ILR/MCOT - Not Medically Necessary

    Not covered when any of the following apply:

    Monitoring asymptomatic individuals for risk factors for arrhythmia

    Expanded not medically necessary statement

    Monitoring for effectiveness of antiarrhythmic medications
    Detection of myocardial ischemia by detecting ST-segment changes
    Any other indications not specified as medically necessary

    Not Medically Necessary — Expansion

    Policy expansions clarifying not medically necessary uses:

    Site of Service Criteria and Clinical Risk Factors

    Site of Service Criteria for ILR Implantation

    Site of service considered medically necessary when ONE of the following applies:

    Ambulatory surgical center (preferred) when appropriate

    Preferred site for elective ILR when criteria met

    Off campus-outpatient hospital/medical center if no qualifying ASC within 30 miles that can provide necessary care (no geographically accessible ASC with necessary equipment, or ASC where physician has privileges, or ASC guideline prohibits use related to individual's health/weight)30 miles
    On campus-outpatient hospital/medical center when no access to ASC per above; or individual aged 18 or younger; or service performed with additional service requiring hospital outpatient department; or individual has clinical condition increasing risk for complications

    Clinical risk conditions listed separately

    Indications and Operational Criteria

    Medically Necessary Indications (MCOT / Mobile Cardiac Telemetry and ILR)

    Covered when ALL of the following are met:

    Evaluation of recurrent unexplained clinically significant presyncope, syncope, severe palpitations or dizziness when symptoms are thought to be due to a cardiac arrhythmia as the most likely diagnosis

    Symptoms thought to be due to arrhythmia required

    Prior non-diagnostic monitoring: Holter monitor and/or external ambulatory event monitor (AEM) has been nondiagnostic or contraindicated; for ILR specifically: prior non-diagnostic or inconclusive ambulatory cardiac monitoring of at least 14 continuous days>= 14 continuous days for ILR

    Added to ILR criteria effective Aug. 7, 2026

    Documentation that real-time monitoring is essential for patient safety and will lead to immediate clinical changes such as medication or other emergent procedures

    Applies to MCOT scenarios where immediate management changes expected

    Coding

    ILR Procedure CPTCPTCovered
    33285Insertion, subcutaneous cardiac rhythm monitor, including program.
    MCOT Monitoring CPTCPTCovered
    93228External mobile cardiovascular telemetry with electrocardiographic recording, concurrent computerized real-time data analysis and >24 hours of accessible ECG data storage; review and interpretation with report by a physician or other qualified health care professional.
    93229External mobile cardiovascular telemetry with electrocardiographic recording, concurrent computerized real-time data analysis and >24 hours of accessible ECG data storage; technical support for connection and patient instructions for use, attended surveillance, analysis and transmission of daily and emergent data reports.
    HCPCS Device CodesHCPCSCovered
    C1764Event recorder, cardiac (implantable).
    E0616Implantable cardiac event recorder with memory, activator, and programmer.
    Added CPT / HCPCS codesmixed
    33285CPT code added for implantable loop recorder.
    C1764HCPCS code added to policy for implantable device.
    E0616HCPCS code added to policy for implantable device and programmer.
    Added CPT code for ILRCPT
    33285CPT code added to policy for implantable loop recorder (historical note).
    Added HCPCS codesHCPCS
    C1764HCPCS added to policy (code listed in history).
    E0616HCPCS added to policy (code listed in history).
    Removed CPT codes (historical)CPT
    0295TRemoved from policy (coding update noted 03/23/17).
    0296TRemoved from policy (coding update noted 03/23/17).
    0297TRemoved from policy (coding update noted 03/23/17).
    0298TRemoved from policy (coding update noted 03/23/17).
    Site of Servicemixed
    SOS ASCAmbulatory surgical center (preferred) site-of-service for ILR implantation; policy includes criteria for when hospital outpatient settings are acceptable or not; site-of-service review does not apply to IHS facilities.

    Provider Actions & Billing Impact

    Prior Authorization

    Prior authorization and site-of-service review for ILR

    Prior authorization and site-of-service review is required for elective ILR implantation. Verify prior authorization before scheduling the procedure. Site-of-service review applies to determine the most appropriate outpatient location (ASC preferred); note that site-of-service review does not apply to Indian Health Service (IHS) facilities.

    • Affected codes: 33285, C1764, E0616
    • Site-of-service review does NOT apply to IHS facilities
    Documentation Required

    Medical record documentation required

    Medical record documentation must demonstrate that all policy medical necessity criteria are met, including symptom history, prior monitoring, and workup when relevant. Documentation should support that monitoring is likely to change management.

    • Include office visit notes with relevant history and physical

    Background, Evidence & Definitions

    Background: ILRs and MCOT provide extended outpatient cardiac monitoring to detect intermittent arrhythmias not captured by brief in-office tests. ILRs offer long-term, automatic rhythm surveillance (months to years) while MCOT provides continuous real-time transmission and analysis for up to ~30 days.

    This policy focuses specifically on when each technology (ILR versus MCOT) is medically necessary versus not, and limits its scope to those two device classes rather than the broader array of ambulatory monitors.

    Evidence / SourceSummary
    RCTs/Observational evidence for ILRStudies report higher arrhythmia detection with ILR versus shorter-term monitoring; evidence sufficient to show improvement in diagnostic yield and net health outcome when prolonged monitoring is needed.
    RCTs for MCOTOne RCT (Rothman 2007) compared MCOT with standard loop event monitoring, showing higher detection rates for MCOT but unclear impact on clinical outcomes.
    Large observational MCOT detection ratesLarge retrospective and cohort studies report higher diagnostic yield for MCOT (e.g., Favilla 2015: 14% AF detection after cryptogenic stroke; Kadish 2010: ~1% potentially emergent events during monitoring); observational data show increased arrhythmia detection but limited outcome data.
    Guideline recommendationACC/AHA/HRS and other societies state that external cardiac monitoring approaches including MCOT can be useful for selected patients with syncope (Class IIa) and that ILR may be reasonable for extended monitoring after cryptogenic stroke.
    AAN recommendation / Stroke guidanceAAN: clinicians might obtain outpatient cardiac rhythm studies in cryptogenic stroke and prolonged monitoring (≥1 week) may increase yield (Level C).
    Literature review dateLiterature review and policy updated through August 29, 2025 and December 2, 2025 with subsequent policy revisions effective April 8, 2026 and August 7, 2026.
    TermDefinition
    MCOTMobile cardiac outpatient telemetry: continuously recording or autotriggered memory loop devices that transmit data to a central recording station with real-time monitoring and analysis.
    ILRImplantable loop recorder: implantable memory loop device providing long-term automatic rhythm surveillance, patient- or auto-activated; subcutaneous implantable cardiac monitor for extended rhythm surveillance.
    Non-diagnostic ambulatory cardiac monitoringPrior external ambulatory cardiac monitoring (e.g., event monitor) of at least 14 continuous days that did not establish a diagnosis.
    AEMAmbulatory Event Monitor — term removed from policy for clarity (AEM removed from policy).
    Mobile Cardiac TelemetryExternal real-time ambulatory cardiac monitoring with streaming and immediate alarm generation (synonymous with MCOT in this policy).

    Medicare Determinations

    EffectiveNameNumberType
    2004Electrocardiographic Services20.15NCD

    Revision History

    2026-08-07policy_revision/effectiveLatest

    Policy revised effective Aug. 7, 2026; header indicates revision and effective date; updated site-of-service and medical necessity criteria for ILR and MCOT.

    2026-08-07criteria_addedLatest

    Added requirement that ILR placement requires prior non-diagnostic or inconclusive ambulatory cardiac monitoring of at least 14 continuous days before ILR is considered medically necessary.

    Policy Summary
    PayerPremera Bluecross
    PolicyMobile Cardiac Outpatient Telemetry and Implantable Loop Recorders
    Policy CodePolicy 2.02.510
    Change TypeRevised / Added criteria (ILR addedcoding updates)
    Effective DateAug 7, 2026
    Last ReviewJun 1, 2026
    Next Review DateN/A
    Key ActionDocument prior >=14-day non-diagnostic ambulatory monitoring and relevant symptoms or cryptogenic stroke workup in office visit notes to support medical necessity for ILR/MCOT.
    SourceLink
    On This Page
    Coverage SummaryImplantable Loop Recorder (ILR) — Medically NecessaryMobile Cardiac Outpatient Telemetry (MCOT) — Medically NecessaryNot Medically Necessary / Expanded ExclusionsSite of Service Criteria and Clinical Risk FactorsIndications and Operational CriteriaCodingProvider Actions & Billing ImpactBackground, Evidence & DefinitionsMedicare DeterminationsRevision History

    Implantable Loop Recorder (ILR) — Medically Necessary Criteria (summary of added criteria)

    Concise summary emphasizing added prior monitoring requirement for ILR:

    ILR placement meets clinical indications per policy AND prior non-diagnostic or inconclusive ambulatory cardiac monitoring of at least 14 continuous days has been performed>= 14 continuous days

    Summarizes added ILR criterion effective Aug. 7, 2026

    Mobile Cardiac Outpatient Telemetry (MCOT) / Mobile Cardiac Telemetry — Policy change summary

    Policy change affirmation:

    MCOT is considered medically necessary when the policy clinical criteria are met (detailed criteria in policy) and real-time monitoring is essential to patient safety or management

    Short affirmation of coverage when detailed criteria satisfied

    Monitoring of asymptomatic individuals

    Explicitly included in expanded not medically necessary statement effective Aug. 7, 2026

    Use of ILRs when ILR criteria are not met (including without required prior >=14 day non-diagnostic ambulatory monitoring)>= 14 continuous days required for ILR

    ILRs added to expanded not medically necessary expansion

    Claims for monitoring asymptomatic individuals are listed as expanded not medically necessary and may be denied.

    Similarly, ILR placement without documentation that a prior non-diagnostic or inconclusive ambulatory cardiac monitoring period of at least 14 continuous days has been performed may be considered not medically necessary and subject to denial per provider guidance requiring evidence of prior monitoring.

    Sites considered not medically necessary for elective ILR when criteria not met:
    Off campus-outpatient hospital/medical center or On campus-outpatient hospital/medical center when site criteria not met; Inpatient hospital/medical center for elective ILR

    Inpatient elective ILR not medically necessary

    Clinical conditions increasing risk (affecting site of service decision)

    Any one of the following may justify hospital outpatient setting (clinical conditions increasing risk):

    Anesthesia Risk: ASA classification III or higher; personal history of complication of anesthesia; documentation of alcohol dependence or history of cocaine use; prolonged surgery (>3 hours)
    Cardiovascular Risk: Uncompensated chronic heart failure (NYHA class III/IV); recent MI (<3 months); poorly controlled/resistant hypertension; recent cerebrovascular accident (<3 months); increased risk for cardiac ischemia (DES <1 year or angioplasty <90 days); symptomatic cardiac arrhythmia despite medication; significant valvular heart disease
    Liver Risk: Advanced liver disease (MELD Score greater than 8)MELD > 8
    Pulmonary Risk: COPD (FEV1 <50%); poorly controlled asthma (FEV1 <80% despite treatment); moderate to severe obstructive sleep apnea (OSA)COPD FEV1 <50%; Asthma FEV1 <80%
    Site-of-Service Risk Thresholds
    MELD Score> 8
    COPD (FEV1)FEV1 < 50%
    Asthma (FEV1 despite treatment)FEV1 < 80%

    Medically Necessary Indication - Cryptogenic Stroke

    Covered when ALL of the following are met:

    Evaluation of cryptogenic stroke thought to be caused by atrial fibrillation
    Prior non-diagnostic short-term monitoring: Nondiagnostic 24- to 48-hour Holter monitor OR nondiagnostic 48-hour telemetry prior to extended monitoring/ILR24-48 hour Holter or 48-hour telemetry nondiagnostic

    Required before ILR in cryptogenic stroke AF evaluation

  1. Document symptom type and frequency (presyncope, syncope, palpitations, dizziness)
  2. For cryptogenic stroke AF evaluation, document a negative standard workup for AF including 24-hour Holter monitoring
  3. Billing Rule

    Use specified CPT/HCPCS codes

    Use the specified CPT and HCPCS codes when billing for ILR insertion and MCOT services. Report ILR insertion with the appropriate CPT/HCPCS and report MCOT monitoring using the external mobile telemetry CPTs.

    • CPT/HCPCS codes to use: 33285, 93228, 93229, C1764, E0616
    • Report ILR insertion with 33285 or HCPCS C1764/E0616 as applicable
    • Report MCOT services with 93228 and 93229 per technical and professional components
    Note

    Site of service selection for ILR implantation

    Select the most appropriate outpatient site of service for elective ILR implantation. An ambulatory surgical center (ASC) is the preferred site when available and clinically appropriate. Hospital outpatient departments (on-campus or off-campus) may be used only when ASC access is not available or the patient meets listed clinical exceptions. Inpatient elective ILR implantation is considered not medically necessary.

    • Preferred site: Ambulatory Surgical Center (ASC)
    • Hospital outpatient (on-campus or off-campus) allowed only if no ASC within 30 miles with necessary capability/privileges, the patient is ≤18 years, procedure is combined with another requiring hospital setting, or patient has documented increased risk for complications
    • Inpatient elective ILR implantation is not medically necessary
    Denial Risk

    Denial risk for asymptomatic monitoring

    Claims for monitoring that lack documented symptoms or other indications consistent with policy (i.e., asymptomatic surveillance or routine risk-factor screening) may be denied. Ensure the medical record demonstrates symptomatic complaints or evaluation for cryptogenic stroke as specified.

    • Denial risk for claims submitted for asymptomatic monitoring, screening, or routine surveillance
    • Ensure documentation shows symptoms or cryptogenic stroke AF evaluation with prior 24-hour Holter as required
    Documentation Required

    Document prior nondiagnostic monitoring

    Document prior nondiagnostic external ambulatory cardiac monitoring before ILR implantation. The record must show at least 14 continuous days of prior non-diagnostic or inconclusive ambulatory monitoring for ILR candidates and that real-time or prolonged monitoring would likely change management.

    • Prior nondiagnostic external monitoring >= 14 continuous days is required before ILR implantation
    • For MCOT, prior external ambulatory monitoring of at least 14 continuous days with a non-diagnostic outcome is required
    • Documentation should state that further monitoring (ILR or MCOT) will meaningfully affect diagnosis or management
    2026-08-07policy_expansionLatest

    Expanded not medically necessary policy statement to explicitly include ILRs and monitoring of asymptomatic individuals.

    2026-04-08title_and_code_changes/effective

    Effective April 8, 2026 (90-day provider notice): Title changed to Mobile Cardiac Telemetry and Implantable Loop Recorders; ILRs added as medically necessary when criteria are met; CPT 33285 and HCPCS C1764, E0616 added; SOS ASC added for ILR site-of-service.

    2026-05-01administrative_clarification

    Administrative clarification May 1, 2026: minor edits clarifying site-of-service review applies only to ILRs and does not apply to Indian Health Services (IHS) facilities; removed term Ambulatory Event Monitor (AEM) for clarity.

    2026-04-14minor_edits

    Minor ILR criteria edits April 14, 2026 to improve clarity (administrative/language changes).

    Historicalcoding_update/history

    Coding updates included addition of CPT 33285 and HCPCS codes C1764 and E0616 for ILR and HCPCS device codes listed in coding section.