Save Patient Access to Vein Care
We need your attention to a serious matter that we are all facing. Vein care practices are facing a payment crisis of a 22% reduction to the current 2021 Medicare payment across almost all of the superficial and deep venous CPT codes effective January 1, 2022. If this were to occur, we could expect commercial payments to drop, as these typically will mirror Medicare rates in time.
Our AVLS Healthcare Policy Committee has made it clear that the proposed 2022 Medicare reimbursement cuts will reverberate for years on office-based care if they are enacted as proposed. Many office-based clinics would not be able to survive once these cuts spill over to Medicare Advantage and non-Medicare payers. Could your practice?
Along with other partner specialties, AVLS is mobilizing to protect patient access and fair payment. The AVLS is executing now on both a regulatory front and a legislative front, but our efforts will require urgent funding that is above and beyond normal member dues. Your contribution will directly fund Federal emergency advocacy efforts to de fend fair payment and patient access to care.
The societal partners have engaged consultants and lobbyists familiar with CMS and Congress. The plan of attack is two-pronged:
Money makes this happen. Your donation will directly fund legislative initiatives and our consultants.
Get involved by providing the needed financial resources to allow the AVLS that benefits yourself and your colleagues. The Save Patient Access to Vein Care Defense Fund ensures appropriate vein care payment and your patients' access to care for years to come.
As an example, the proposed 2021-2022 CMS reduction in CPT code 36475 (Radiofrequency, 1st vein treated) will be about $302 in the office setting for every claim. To protect your practice and your patients, your AVLS Leadership is urgently asking you to contribute today. A contribution to the Save Patient Access to Vein Care Defense Fund could be the best investment you ever made.
Thank you for supporting the AVLS!
By Dr. Stephen Daugherty, AVLS Healthcare Policy Committee Chair, AVLS Board Director
Office-based vein doctors have experienced decade-long series of payments reductions for superficial vein procedures, and we are now facing a new set of unprecedented reductions that will challenge the survival of many outpatient vein care practices.
Medicare & Medicaid Services (CMS) recently proposed deep, 22% payment reductions to office-based vein care codes in the Proposed Physician Fee Schedule (PFS) Rule for CY2022. To be clear, these reductions impact a gamut of services in the office setting- arterial, IVUS, venous stenting, dialysis access, etc. These cuts are being driven primarily by a change in 2022 office-based RVU calculations in Medicare’s methodology that recognizes undervalued clinical labor data for office-based physicians. However, because of the budget-neutral nature of the national Part B pool, the CMS “pay-for” drastically reduces payment for these vein codes because of the proposed change in the way that the clinical labor data is incorporated into the Physician Fee Schedule. Part B resources are then shifted into other domains of medical care. This proposed CMS adjustment represents the additional reduction, on top of the RUC review of supplies and equipment that have taken place over the past decade or so, and the CMS project that went into effect in 2019 to adjust supplies and equipment costs for many items.
Conversion Factor: CMS is proposing a 3.75% decrease to the Conversion Factor, from $34.89 to $33.58. The CF is used to multiply all NF RVU values to determine payment.
The AVLS will comment to CMS and is working with other provider organizations to urge CMS and Congress to retain the 3.75% increase to the conversion factor (CF) contained in the 2021 MPFS through FY 2023, as mandated by the Consolidated Appropriations Act, 2021 (P.L.116-260). The CAA was signed into law on 12/27/20.
|Code||Abbreviated Code Descriptor||2021 NF Total RVU||2021 Avg. National Payment in NF||Proposed 2022 Total NF RVUs||Proposed 2022 Avg. National Payment||Payment % Change from 2021 vs. 2022|
|36465||NC Foam, Single Truncal Vein||44.29||$1,545||35.87||$1,205||-22.05%|
|36473||MOCA, 1st Vein||41.31||$1,441||33.34||$1,120||-22.32%|
|36475||RF, 1st Vein||37.76||$1,318||30.25||$1,016||-22.89%|
|36478||Laser, 1st Vein||31.74||$1,108||27.78||$933||-15.76%|
|36482||Chem. Adhesive, 1st Vein||55.63||$1,941||45.18||$1,517||-21.83%|
NF = Non-Facility, or office site of serviceView Impact for All Venous Codes
Additionally, because of the expiration of the late 2020 Congressional action that adjusted the Conversion Factor for 2021, payment will be further driven down because of the proposed 2022 Conversion Factor.
Procedural medicine stands opposed to these cuts, and AVLS is advocating for our members to obtain fair reimbursement in 2022 and beyond.
AVLS members who want additional detail about the proposed CMS payment changes may want to listen to the Vodcast that appeared in the Venous Edge online journal.
By Dean Bender, AVLS Executive Director
Robert White, AVLS Director of Advocacy
Since the release of the CMS proposed Part B rule for 2022, the leadership and staff at AVLS have been hard at work understanding the impact on our field and developing a strategy to provide patient access and fair reimbursement while avoiding expected payment reductions over the next few years should this proposal go into effect. One thing that is very clear is that this is an advocacy challenge that will be fought on multiple fronts and that will require every member of the AVLS to become engaged at one level or another.
As of this communication, there are three major efforts underway:
For the AVLS to make our case, we need to quickly fund the data research to support our arguments and to fund the legislative expertise needed to navigate Capitol Hill.
The first stage of our defense was to provide a direct response on behalf of our membership and the field in general to the Centers for Medicare Services (CMS). Our team developed a strategy to support the position that the 2022 Part B Proposed Rule should not be implemented as written because of the significant impact it will make on patient access to office-based specialty vein care. To support this argument, the AVLS is investing in two key pieces of economic research:
Because of the severity of the impact of the Proposed Rule, the AVLS also understand the need to approach this fight with Congressional support. As such, the AVLS has partnered with United Specialists for Patient Access (USPA), a professional association of office-based specialty interests dedicated to advocating for access and fair reimbursement for office-based care. USPA is a coalition of office-based specialties fighting to protect the payment structure of the Physician fee schedule. Led by Jason McKitrick and Liberty Partners, USPA is active on Capitol Hill, targeting congressional education. AVLS has taken an Executive membership position with the Coalition, providing a direct voice among the various members and encouraging other large venous-related groups to join the USPA.
Additionally, we need every member to engage with their local legislators to educate them on the impact of the Proposed Rule and request their support in protecting the future of office-based specialty care. Please join our efforts by:
It is imperative that AVLS develops the financial resources in preparation to act quickly once the CMS Final Rule is released in November. Please give to the Save Patient Access Defense Fund. If we get 300 members to donate their revenue from a single thermal ablation, then we will be able to build a defense fund that is ready to act!
Thank you to those who have donated! As of October 26, the Save Patient Access Defense Fund has amassed $111,656 in donations from 116 donors. We want to thank our members who have joined our defense by not only reaching out to their networks and representatives but also by committing their finances to the Defense Fund. We ask you to join these leaders in our Society by donating today.
To inform our Policy Committee with some additional information, we are asking office-based members to share their input by completing this short survey. Your responses will be kept confidential.
Engage with your member of Congress about this topic. Post this issue in all your office reception rooms and encourage your patients to also contact their Congress representatives! Discuss this issue with your patients if the opportunity presents itself. This is a critical patient access issue, and so it is right to discuss especially with your Medicare patients! Attend a district Town Hall to raise your concerns. Best of all, call and request a 20-minute-or-so meeting in the representative’s district office with the member and their staff. Make a random stop by your representative's district office! Get their attention any way you can.
Attached is suggested text that you can use in your email or request to meet. I recommend customizing your letter to your practice, such as location(s) and the number of staff you employ.
November 10, 2021
8:00 PM EDT
The AVLS Advocacy Committee and our consultants will review and explain the Final 2022 Physician Fee Schedule for Part B services. We will also address our next steps as a Society and how you can get involved.
The AVLS Advocacy Committee hosted an informational webinar to update our membership about the Proposed 2022 Payment Rule on Thursday, August 26, at 8:00 PM EDT. Registration is free, and the webinar recording is restricted to AVLS Members only.Watch the Recording