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Coalition Urges CMS to Not Finalize Clinical Labor Policy in 2022 PFS Proposed Rule

Sep 9, 2021

Unless CMS and Congress take action, proposed cuts of an estimated 23% will drive healthcare consolidation, increase costs, and exacerbate healthcare inequities  

Washington, D.C. –– A group of 16 influential professional groups and societies representing providers across the specialty provider space – including the CardioVascular Coalition – are urging the Centers for Medicare & Medicaid Services (CMS) to not finalize the clinical labor policy included in the 2022 Physician Fee Schedule (PFS) proposed rule.  

As a direct result of CMS’ “budget neutrality” policy, several specialty providers, including providers of revascularization services, face troubling cuts of an estimated 23% — a major blow that comes on top of years of successive, cumulative cuts and amid a historic pandemic that continues to disrupt patient care. To ensure access to specialty care, the groups are asking CMS to address the cuts by not finalizing the clinical labor policy included in the 2022 PFS proposed rule and by coordinating with Congress on fundamental reform to the PFS through legislation this year. 

If left unaddressed, some organizations warn that the massive, proposed cuts would have serious implications including higher costs, increased consolidation among health providers, decreased competition, more volatility, and exacerbated disparities for communities of color.  

“Successive, cumulative cuts to specialists under the PFS are resulting in reimbursement ever more out of touch with actual resource needs as well as increased healthcare consolidation and healthcare costs, greater health inequities, and a healthcare system unable to meet the challenges of an ongoing pandemic,” a United Specialists for Patient Access (USPA) stakeholder letter signed by the CVC stated. 

To address the proposed cuts, the organizations call on CMS to not update clinical labor data in the 2022 PFS final rule, which would automatically invoke the budget neutrality provision and cause severe cuts of more than 20% to critical services under the PFS system. Additionally, the organizations urged CMS to work with Congress to fundamentally reform the PFS so that the “budget neutrality” provision in the 2021 PFS Final Rule E/M policy cannot continue causing negative impacts in the form of a scheduled 3.75% cut to the conversion factor in 2022. Groups opposing CMS’ clinical labor proposal include: 

  • American College of Radiation Oncology 

  • American Society of Diagnostic and Interventional Nephrology  

  • American Vein & Lymphatic Society 

  • American Venous Forum 

  • Alliance for Physical Therapy Quality and Innovation  

  • Association of Black Cardiologists 

  • CardioVascular Coalition 

  • Dialysis Vascular Access Coalition


  • The Fibroid Coalition 

  • Outpatient Endovascular and Interventional Society 

  • Preventive Cardiovascular Nurses Association 

  • Renal Physicians Association 

  • Society for Cardiovascular Angiography & Interventions  

  • Society of Interventional Radiology 

  • Society for Vascular Medicine 

  • United Specialists for Patient Access 

To read the USPA coalition letter, CLICK HERE


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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