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CVC: Clinical Labor Cuts in Final PFS Rule Threaten Patient Access to Amputation Prevention Measures

Nov 12, 2021

Vascular care leaders urge Congressional action to prevent implementation of deep Medicare cuts to specialty care services in 2022

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 disappointment in the Centers for Medicare & Medicaid Services’ (CMS) Final Physician Fee Schedule (PFS) Rule for CY 2022 that finalizes severe cuts to amputation prevention procedures, including revascularization. The vascular care community plans to immediately seek legislative solutions to ensure these cuts are not implemented as planned in 2022.

“We continue to have significant concerns with the cuts finalized by CMS this week, which we have warned could negatively impact clinical outcomes, limit patient choice, and ultimately drive providers out of business,” said Dr. Jeff Carr, CVC Board Member. “Despite strong, bipartisan opposition to these cuts and the threats they pose to healthcare equality and consolidation, it is upsetting that CMS chose to move forward with these policies. We now look forward to working with our champions in Congress to address these harmful payment cuts before they take effect in 2022.”

On September 13, Representatives Bobby Rush (D-IL), Gus Bilirakis (FL), and 73 of their House colleagues sent a letter to CMS urging the agency not to finalize the cuts to specialty care providers included in the proposed 2022 Medicare Physician Fee Schedule (PFS). The lawmakers expressed particular concern on the cuts’ impact on minority health. According to the letter, cuts of 22% to reimbursement for revascularization services will harm Black and Latino Medicare beneficiaries who are three times more likely and twice as likely, respectively, to receive an amputation due to peripheral artery disease. 

Limiting patient 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.

The main driver of payment cuts in the 2022 PFS Final Rule are CMS’ updates to 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 22% over four years to critical revascularization services at a time when patients are choosing to access health services in outpatient facilities that are convenient and less costly. 

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