SVS submits comment letter on Medicare fee schedule to CMS


In September, the Society for Vascular Surgery submitted a detailed comment letter to the Cen­ters for Medicare and Medicaid Services (CMS) in re­sponse to a proposed rule that could mean a 3–4% cut in Medicare payments.

The letter responds to CMS’ Calendar Year (CY) 2024 Medicare Physician Fee Schedule Proposed Rule (MPFS). SVS members are urged to address lawmakers on the issues, via grassroots advocacy. Pre-written messages are available at

Depending on practice setting, vascular surgeons face a 3 to 4% cut based on current Medicare policies proposed in the MPFS rule.

These cuts result from a reduction in the temporary update to the conversion factor under current law and a negative budget-neutrality adjustment stemming in large part from CMS moving forward with implementation of separate pay­ment for add-on code G2211 to account for visit complexity associated with certain office/outpatient evaluation and management visits. The code was initially proposed three years ago, but implementation was delayed as a result of an aggressive advocacy campaign led by surgical societies, including the SVS.

In addition, payment reductions for many vascular sur­geons are compounded by the third year of CMS’ phased-in implementation of its clinical labor pricing update, which was finalized in the CY2022 MPFS Final Rule.

“Systemic issues such as the negative impact of the Medi­care physician fee schedule’s budget neutrality requirements and the lack of an annual inflationary update will continue to generate significant instability for health care clinicians moving forward, threatening beneficiary access to essential health care services,” the letter includes.

The SVS, in collaboration with medical specialty societies, is continuing to work to mitigate the scheduled cuts and advance policies to stabilize the payment system in the short term and reform the system for the future.

To that end, the SVS supports legislation to provide an inflationary update for the MPFS (H.R. 2474) and is leading the effort that brought forth the introduction of legislation to provide targeted relief for codes most impacted by the clinical labor update policy (H.R. 3674).

The SVS is also seeking further delay of the G2211 code implementation via both regulatory and legislative initiatives.

Read the letter to CMS at


Please enter your comment!
Please enter your name here