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July 28, 2021  

Contact: Grant Herring
(202) 552-1708‬  

Coalition of Specialty Providers Warns Proposed 20% CMS Cuts To Office-Based Specialists Will Lead To A Surge in Health System Consolidation, Exacerbate Health Inequity and Reduced Patient Choice

The United Specialists for Patient Access says the flawed PFS methodology and the deep cuts proposed by the Centers for Medicare & Medicaid Services (CMS) threaten to drive office-based providers out of business and reduce Medicare beneficiary access. 

WASHINGTON – The United Specialists for Patient Access (USPA) – a coalition of practitioners and affiliated entities involved in providing office-based specialty care – is sounding the alarm regarding painful 20% payment cuts to critical services in the proposed Physician Fee Schedule (PFS) Rule for CY2022.  

A second-order effect of a CMS proposal to update clinical labor data in the PFS, the 20% cuts are caused primarily from the so-called PFS “budget neutrality” provision — a misnomer that camouflages the impact to frontline office-based providers.  PFS “budget-neutrality” also was a second-order effect from the 2021 CMS “E&M” policy resulting in a massive 10% across-the-board cut to the PFS and has been driving huge reimbursement reductions over the last decade for a number of specialties, including cardiology, physical therapy, radiation oncology, radiology, and vascular surgery, among others.  PFS “budget-neutrality,” which is badly in need of reform, is also a catalyst in driving health inequities, health system consolidation, and creating higher Medicare costs. 

Dr. Mark Garcia, USPA Board Member and Health Policy Advisor, stated, “While the Biden Administration is trying to take proactive steps to address structural inequities in our healthcare system, this CMS proposal on the PFS is a stumbling block. Many of the services affected by this CMS cut will impact Black, Latino, and other people of color the hardest. This misguided “budget-neutrality” formula is setting in motion a downward spiral in the quality of care for patients.”


Dr. Garcia continued, “The proposed cut of 20% is also adding fuel to the fire of health system consolidation. The result will be reduced healthcare choice for all patients and even less for minority communities. Many specialists who serve minority populations will be forced to close their doors due to inadequate federal reimbursement and instability.  On top of this, the COVID-19 pandemic is not yet behind us and threatens a resurgence.  We learned last year how important it was to make sure office-based interventions are viable so hospitals can focus on COVID-19 patients.”


The USPA strongly urges CMS not to finalize the clinical labor policy in the 2022 PFS Proposed Rule as the second-order negative impacts far outweigh any benefit from updated clinical labor data at this time.  Moreover, considering PFS “budget neutrality” effects from the 2021 PFS Final Rule E/M policy are still causing negative impacts in the form of a scheduled 3.75 percent cut to the conversion factor in 2022, we urge CMS to work with Congress on fundamental reform to the PFS so that Congress may better address the upcoming 3.75 percent cut in legislation later this year.


About the United Specialists for Patient Access (USPA): USPA is a coalition of practitioners and affiliated entities involved in providing office-based specialty care. More information about USPA is available at   




About the United Specialists for Patient Access (USPA) 
The mission of United Specialists for Patient Access is to unify and strengthen the voice of office-based specialists, enabling professionals and patient advocates to work collaboratively with Congress and the Administration and achieve near-term relief and long-term payment stability in the Physician Fee Schedule.  For more information, please click here: 

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