SCAI has provided a brief overview of the MPFS in connection with interventional cardiology below. In addition, the statement below regarding CY 2022 Proposed Codes for Vascular and Revascularization Cuts includes a description of how we are battling these proposed cuts and how you can help.
Medicare Physician Fee Schedule (MPFS)
CY 2022 Conversion Factor
SCAI will urge CMS to maintain the 3.75% increase (from 2021) through at least CY 2023. SCAI will file comments in September urging CMS to continue to waive the budget neutrality adjustment in light of the uncertainty of the COVID-19 Public Health Emergency (PHE). SCAI is actively working with the American Medical Association and other specialty physician coalitions and is signing on to letters to Congress opposing the increase. A table containing the Vascular Codes affected by these Clinical Labor Cuts is provided here.
CY 2022 Proposed Codes for Vascular and Revascularization Cuts
SCAI will strongly urge CMS to reverse the proposed payment cuts, estimated as high as 20-30 percent, to revascularization services in the proposed rule by CMS. We will point out that CMS not only risks creating worse outcomes for patients, increase the likelihood of higher health spending, increase health system consolidation, and extend persistent health care inequities.
Background: Roughly 85 percent of amputations in the US are preventable when people with PAD have access to timely vascular care and revascularization services. Despite the life-changing impact of preserving peoples’ limbs, the proposed slashing of payments to a variety of specialty providers that treat patients with vascular disease would result in dire consequences for patient access.
We have joined a coalition effort to fight these severe cuts and launched a SCAI member effort to support the “Dear Colleague” letter, written by Reps. Rush (D-IL) and Bilirakis (R) to their fellow Members of Congress, telling CMS not to implement these severe cuts to vascular services. View the letter here.
Clinical Labor Cost
SCAI has been participating in a Coalition with SVS, SIR, ACR, ACC, and other societies who are putting together appropriate language regarding the Clinical Labor cost that will bring steep cuts for vascular interventions. We are developing language so we can all send a similar message to CMS regarding the cuts. Background: The clinical labor costs have not been adjusted in 20 years and it is appropriate to review the costs. Nevertheless, we will urge CMS to do so in a more timely fashion going forward and suggest a phased-in approach to the current cuts over the next four years. Rough calculations suggest that we may be looking at between a 14–16% cut. The comparison table in the proposed rule includes vascular services which are the codes of concern because they are mostly office. Societies are collecting “vignettes/patient stories” such as articles proving that patient’s seen in the office for venous issues do better and avoid the hospital, etc.
CY 2022 Proposed Codes, Valuation of Specific Codes
SCAI will support CMS's decision to accept the RUC recommended values for new codes for Percutaneous Cerebral Embolic Protection and Exclusion of Left Atrial Appendage. SCAI will strongly recommend that CMS accept the RUC recommended values for new codes for Endovascular Repair of Aortic Coarctation and Cardiac Catheterization for Congenital Defects in our comments.
Telehealth Services
SCAI will commend CMS on their proposal to retain all services that were added to the Medicare Telehealth Services list until the end of CY 2023. We will also urge CMS to allow continued access to these telehealth services after the PHE.
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