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Sep 15, 2026
Washington, DC — On September 14, the CardioVascular Coalition (CVC) submitted a comment letter to Centers for Medicare & Medicaid Services (CMS) on the CY 2027 Physician Fee Schedule (PFS) Proposed Rule. In its letter, CVC, whose members include providers and industry representing physicians and staff in 45 states at more than 378 centers where minimally invasive cardiovascular care is delivered, calls on CMS to pursue structural reform of the PFS, warning that an outmoded fee schedule is driving consolidation and threatening patient access to low-cost, office-based care for peripheral artery disease and coronary artery disease.
CVC's letter responds directly to CMS's own acknowledgment in the proposed rule that “recent trends in physician employment and consolidation have shifted a growing share of specialists into health system-affiliated or other integrated organizational arrangements, rather than independent practice.” CVC agrees with CMS's assessment, citing data showing that 82% of physicians were employed by hospitals or corporate entities as of January 1, 2026, and that the number of independent rural physicians fell 43% between 2019 and 2024.
READ THE COMMENT LETTER
CVC CY 2027 PFS Proposed Rule Comment Letter (CMS-1848-P) • .pdf
The letter states, in part, “It's in the name: the ‘Physician Fee’ schedule was established in 1992 to handle professional fees for physicians practicing in their chosen site of service… However, as this multi-decade trend progressed, funding for such care did not move from the Medicare Hospital Outpatient Prospective Payment System to the Physician Fee Schedule. In other words, the Physician Fee Schedule has been subsidizing the Hospital Outpatient Prospective Payment System for years as practice expense has moved from the hospital setting to the office-based setting.”
The letter goes on to say, “While predictable, inflation-based updates of the PFS conversion factor would support physician work in all sites-of-service, structural reform of the PFS would address how Medicare values office-based practice expense.” It adds, “Medicare already maintains a mature reimbursement methodology for ambulatory practice expense: the Hospital Outpatient / Ambulatory Surgical Center Prospective Payment System… As such, we believe Medicare should pay for office-based practice expense outside of the PFS and consistent with how it pays for other ambulatory practice expenses.”
CVC's modeling of a new office-based facility (OBF) fee schedule projects 10-year Medicare savings of $16.6 billion if 30% of hospital outpatient volume shifts to the office setting, and $31.8 billion at a 35% shift.
The letter makes the following requests:
Create a new OBF fee schedule. “The CVC urges CMS to work with Congress and the Bipartisan Doctors Caucus on policies which would remove office-based practice expense from the Physician Fee Schedule and create a new office-based facility (OBF) fee schedule.”
Remove the indirect practice cost index. CVC “strongly supports the CMS proposal to remove the indirect practice cost index” from the calculation of practice expense RVUs, noting current IPCI values of 0.85 for cardiology, 0.42 for interventional radiology, 0.36 for vascular surgery, and 0.24 for peripheral vascular disease.