I think I'll answer my own question with this response from the HRS:
Thank you for your inquiry.
A correction will be made in the CPT manual for CPT 33225 parenthetical note. Codes 33228, 33229, 33263, 33264 will be added to the list in which code 33225 may be reported as an add-on. In the case of an upgrade to a CRT device when no right atrial/ ventricular lead(s) are inserted/replaced and only the pulse generator is replaced with a new left ventricular lead insertion, code 33225 may be reported with the pulse generator replacement only codes. Code 33229 for an upgrade from single to multi chamber pacemaker device, the code selection should be based on the final device inserted.
An AMA CPT Assistant will be published which will provide documentation of this forthcoming correction. In the interim it may be necessary to work directly the your payer to appeal the claim with this supporting documentation.
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