Sep 9, 2022
CVC comment letter highlights concerns over proposed rule
WASHINGTON, DC — Earlier this week, the CardioVascular Coalition (CVC) submitted official comments to the Centers for Medicare and Medicaid Services (CMS) on the proposed rule for the CY 2023
Physician Fee Schedule (CMS-1770-P).
The CVC letter, addressed to CMS Administrator Brooks-LaSure, emphasizes that ongoing cuts to office-based specialists under the Physician Fee Schedule are contributing to office-based center closures, health system consolidation, and a deepening of the existing health equity gaps.
The letter states, in part, “While the [Biden] Administration has launched a number of initiatives aimed at addressing health inequity through the elimination of disparities in health care, the 2023 PFS Proposed Rule actually threatens to undermine these initiatives in areas throughout the PFS by continuing to phase in the 2022 PFS clinical labor cuts.”
It continues, “The incentive is clear for beleaguered PFS providers who may no longer be able to sustain further cuts in the 2023 PFS Proposed Rule to simply close their centers and continue the migration to large health systems. As noted by the Medicare Payment Advisory Commission (MedPAC), ‘the preponderance of evidence suggests that hospital consolidation leads to higher prices.’”
The CVC comment letter goes on to state, “While ‘budget-neutrality’ sounds like good policy, when it operates within a Physician Fee Schedule that has not kept up with inflation, it results in massive swings in reimbursement and punishes providers irrespective of the value they add to the healthcare system. This is because, while reimbursement under the overall Physician Fee Schedule has increased 11 percent over the last two decades, the cost of running a medical practice has increased 39 percent over that same period.”