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CardioVascular Coalition Notes Proposed 20% Medicare Cut to Amputation Prevention Services Will Increase Health Inequity

Aug 3, 2021

Deep payment cuts proposed by the Centers for Medicare & Medicaid Services (CMS) threatens to reduce access to Medicare beneficiaries at risk for limb loss 

Washington, D.C. –– The CardioVascular Coalition (CVC) – a coalition of physicians, care providers, advocates, and manufacturers working to improve awareness and prevention of peripheral artery disease (PAD) – expressed grave concern regarding deep ~20% payment cuts to revascularization services in the proposed Physician Fee Schedule (PFS) Rule for CY2022.  

 “Revascularization services that treat blood flow to legs and feet are absolutely vital for older Americans at risk of severe arterial blockages and limb loss,” said Dr. Jeff Carr, CVC Board Member. “CMS’ proposed cuts, despite the well-documented improvement in clinical outcomes resulting from revascularization performed in the outpatient setting, are severe, unwarranted, and may limit patient choice, and threaten to drive providers out of business. If the proposed 20% cut is finalized by the agency, the downstream effects on patient access, health system consolidation, and systemic inequities will be devastating.” 

The main driver of payment cuts in the 2022 PFS Proposed Rule relates to a CMS proposal to update clinical labor data.  Hardest hit are cardiology, vascular surgery, venous, radiation oncology, and radiology practices. On its face, updating clinical labor data in the CMS database makes sense. 

Indeed, every specialty under the PFS should be seeing increases to resources based on new clinical data from the Bureau of Labor Statistics.  However, including new clinical labor data results in massive cuts of up to 20% to critical revascularization services at a time when patients are choosing to access health services in outpatient facilities that are convenient and less costly.   

These impacts will have profoundly negative effects on health equity.  The decrease in access to revascularization services could lead to higher amputation rates and exacerbate inequities that already exist, particularly in America’s communities of color.  According to the Dartmouth Atlas, amputation risks for African Americans living with diabetes are as much as four times higher than the national average. Data analyses have similarly found that Native Americans are more than twice as likely to be subjected to amputation and Hispanics are up to 75 percent more likely to have an amputation. 

“As frontline medical professionals dedicated to improving access to quality vascular care, we strongly urge CMS not to finalize the clinical labor policy in the 2022 PFS Proposed Rule as the second-order negative impacts far outweigh any benefit from updated clinical labor data at this time,” continued Dr. Jeff Carr.  “Moreover, considering the 2021 PFS Final Rule E/M scheduled 3.75 percent cut to the conversion factor is still causing negative impacts in 2022, we urge CMS to work with Congress on fundamental reform to the PFS in order that Congress may better address the upcoming 3.75 percent cut in legislation later this year.” 


About the CardioVascular Coalition (CVC) Our mission is to advance patient access to care for peripheral artery disease (PAD). Physicians, care providers, advocates, and manufacturers who comprise the CVC are dedicated to community-based solutions designed to improve awareness and prevention of PAD, reduce geographic disparities in access to care, and secure patient access to high-quality, cost-effective interventional treatment across America. Learn more at 

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