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CVC Sounds Alarm for Office Based Providers in Comment letter

Sep 20, 2023

Washington, DC — The CardioVascular Coalition submitted a comment letter to Chiquita Brooks-LaSure, the Administrator of the Centers for Medicare and Medicaid Services. The CVC continued to sound the alarm to the proposed cuts included in the 2024 Medicare Physician Fee Schedule (MPFS) released in July by the Centers for Medicare & Medicaid Services (CMS).

The CVC believes that the ongoing cuts initiated by CMS pose a significant risk, causing instability and potentially compromising patient access to vital revascularization services, which have proven effective in preventing amputations and reducing overall costs. This reduction in access raises concerns among CVC members, who fear that a decline in availability could hinder many Americans, especially Black, Native, and Hispanic communities, from receiving essential care for PAD.


CVC CY 2024 PFS Proposed Rule Comment Letter (CMS-1784-P)
Download PDF • 648KB

The letter states, in part, “These [MPFS] cuts, in turn, are contributing to: reduced access to office-based specialty care, including in rural and underserved areas, health system consolidation, the undermining of the Administration’s efforts on addressing health equity issues, higher Medicare beneficiary coinsurance, and the undermining of our Nation’s pandemic resilience.”

The letter makes the following request: “In the 2024 PFS Proposed Rule, CMS states continued interest in promoting “stability and predictability” in the PFS. We believe it would be best for CMS to truly “prioritize stability and predictability over ongoing updates” by temporarily freezing the implementation of further policy updates – including the clinical labor policy in 2024 through 2025 and the implementation of G2211 in 2024 – that will result in further significant redistributions to the Physician Fee Schedule. Instead, we urge CMS to focus on fundamental PFS reform.”

Interventional Cardiologist and Endovascular Specialist Jeffrey G. Carr, MD, a CVC Board member, said, "The proposed rule, coupled with the ongoing cuts affecting office-based providers, will have severe repercussions for patients suffering from PAD and CAD. These poor decisions made in Washington are poised to eliminate specialists and reduce patient access to much-needed quality care. As written, the new rule from CMS is likely to exacerbate the health equity gap as it forces office-based providers out of business. With specialists facing recurring cuts, managing record inflation, and still striving to deliver exceptional care to patients with CAD and PAD, the situation becomes unsustainable. It is imperative that Congress takes action on H.R. 3674 to prevent and mitigate these imminent cuts to office-based specialists."

The letter highlights a multi-societal survey distributed across multiple specialties, including vascular surgery, interventional radiology, and interventional cardiology, to predominately non-hospital physicians that found:

  • 87% of respondents “believe Medicare cuts have a moderate or greater impact on the practice,”

  • 53% of respondents “believe the likelihood of the practice’s success is unlikely,”

  • 22% of respondents “are likely to become a hospital employee if cuts continue,”

  • 21% of respondents “are likely to sell their practice if cuts continue,”

  • 17% of respondents “are likely to retire if cuts continue,” and

  • 8% of respondents “retired, sold, or closed their practice from 2021 to 2022.”


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