SIR to CMS: Protect Access to Patient Care, Reverse Devastating Medicare Physician Fee Schedule Cuts

Medicare Physician Fee Schedule Cuts: Proposed cuts to physician reimbursements could shutter practices and leave thousands of medically vulnerable patients without access to care, the Society of Interventional Radiology said in a comment letter submitted to the Centers for Medicare and Medicaid Services (CMS) today.

The letter was submitted in response to the July 13 proposed rule for the 2022 Medicare Physician Fee Schedule (MPFS). Under the proposal, interventional radiologists could see an aggregate cut of 13% for all IR treatments, with certain procedures performed in office-based lab settings experiencing cuts greater than 20%. Treatments with the highest cuts include limb-saving peripheral arterial disease treatments, clot-busting venous treatments, venous stenting, and other vascular work.

“The rule represents a perfect storm resulting from CMS’s decision to allow their labor rates and product cost tables to lag behind inflation,” said SIR President Matthew S. Johnson, MD, FSIR, an interventional radiologist and Gary J. Becker Professor of Radiology Research at Indiana University School of Medicine in Indianapolis. “In many cases, practice costs have not been updated in 20 years. Due to purported budget neutrality, CMS made apparently arbitrary cuts rather than reimburse all practices and specialties at their true cost of care.”

While CMS considers such cuts “budget neutral” they disproportionately affect procedures performed by interventional radiologists in office-based settings, such as treatment of venous ulcers and dialysis access. More importantly, the services most affected treat diseases that disproportionately affect patients of color, such as peripheral artery disease, venous disease, renal disease and cancer.

“As a result, the profound cuts will negatively affect health equity in communities who have already been particularly hard hit by the COVID-19 pandemic,” said Johnson. “By making it difficult for outpatient, office-based labs to continue to operate, patients seeking care will have to do so in hospital settings, which are still reeling from COVID-19. For some patients, this could mean traveling hours outside of their community to receive treatment.”

Throughout the pandemic, office-based facilities have allowed hospitals to focus on the sickest COVID patients while allowing lifesaving cancer treatments and limb-saving vascular procedures to continue. The cuts may make some practices unsustainable, directly impacting readiness for future COVID surges or new pandemics. In addition, office-based lab facilities deliver quality care to patients far from major hospital centers. Community-based, outpatient care allows patients to return to their normal lives sooner.

“We must protect patients’ access to that crucial care and prevent private practices from closing down, especially in underserved areas,” said Johnson.

SIR is joining with other healthcare organizations, such as the American Medical Association, the American College of Radiology, the CardioVascular Coalition and other medical specialty societies, to combat these cuts and plead with CMS and Congress to:

  • Reverse the cuts
  • Suspend sequestration
  • Maintain for 2022 the COVID-19 related increase to the conversion factor to ensure that what is reimbursed better reflects the real cost of healthcare in a pandemic world.
  • Avoid implementing clinical labor pricing revisions at this time. If they must implement it, phase the new rates in over 4 years to minimize the effects on private practices.
  • Adopt RUC reimbursement recommendations for specialty and practice expense codes.

Read the SIR’s full letter to CMS.

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