The Problem

The 2024 Medicare Physician Fee Schedule (PFS) Proposed Rule issued on July 13, 2023, would impose yet another round of significant cuts to office-based specialists. These cuts will continue to accelerate the health system consolidation trend, exacerbate health inequities in a variety of diseases, and threaten the pandemic resilience of our healthcare system. 

“Budget-neutrality” remains a driver of cuts within the fee schedule as the 2024 PFS Proposed Rule incorporates: 

 

• A carry-over 3.4% cut to the conversion factor from the 2021 PFS E/M policy and, 

• The third-year of clinical labor cuts to office-based specialty relative value units (RVUs) from the 2022 PFS Clinical Labor policy that cuts some specialists by another 3%. 

PFS physician payments equal conversion factor * RVUs.  As a result, certain office-based specialists will again be cut by another 6 - 7% in 2024 alone. 

These year-over-year cuts are being implemented without regard to patient outcomes, actual PFS provider resource needs, or any other rationale policy. 

In the 2024 PFS Proposed Rule, CMS states continued interest in promoting “stability and predictability” in the PFS.   We urge CMS and Congress to follow through on this statement and stop ongoing clinical labor and EM cuts to office-based specialists in end-of-year Medicare legislation as Congress looks to undertake the serious work of fundamental reform to the Physician Fee Schedule.