SVS details opposition, support to CMS proposed rules

Nov 08, 2020

By Beth Bales

The Society for Vascular Surgery (SVS) has submitted comment letters to the Centers for Medicare & Medicaid Services (CMS) on two proposed rules that directly affect SVS members: the Medicare Physician Fee Schedule and the Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems (HOPPS).

CMS ISSUED THE PROPOSED RULES in early August. They will be finalized on or around Dec. 1 and effective on Jan. 1, 2021. “The letters provide CMS with our Society’s strong and detailed responses to each vascular policy point in the proposed rules,” said Matthew Sideman, MD, chair of the SVS Policy and Advocacy Council.

The proposed Physician Fee Schedule rule includes cuts that that would reduce total payments to vascular surgeons of 7%. “These rules include cuts that will have a massive impact on vascular surgery practices for years to come,” said Sideman.

“We are fighting back with these letters, plus a partnership with 11 other surgical societies and with outreach to our own members to contact their legislators.”

The SVS letter also contains comments on the proposed rule for Quality Reporting Programs.

Physician Fee Schedule

The SVS strongly opposes the reduction in the conversion factors, from $36.09 this year to $32.26. This is lower than the 1994 factor, which would be approximately $58 in today’s dollars. This cut, paired with upcoming changes in the office/outpatient evaluation and management values in the global codes, could force surgeons who rely on providing care to Medicare patients to be unable to continue to practice.

SVS also opposes other details in the proposed rule, including the E/M Inherent Complexity Add-on Code and CMS’s establishment in global services of a two-tiered system for evaluation and management services.

SVS offered detailed comments on toe amputation services, supply pricing and the technical expert panel related to practice expense.

The letter also addresses the Quality Payment Program, urging CMS to extend flexibility on the “extreme and uncontrollable circumstances hardship exception” through at least 2021, because of the COVID public health emergency and also agrees that CMS should delay the timeline for implementation of any Advanced Alternative Payment Models (AMPs) until at least 2022.

Other issues also are addressed. Read the complete letter at


SVS opposed CMS’ proposal to eliminate the Inpatient Only list over the course of three years. Doing so will “increase patient copayments for many procedures while increasing patient risk.

In contrast, SVS does support an annual process whereby stakeholders nominate services for removal from the IPO list, and due consideration is given to patient safety and patient financial burden.”

The letter also addresses other topics, including changes to the Ambulatory Surgery Center list of covered surgical and dialysis vascular access payments. Read the complete letter at

Healthcare on a precipice: SVS PAC stands ready to fight coming challenges


Since 2002, the SVS Political Action Committee (PAC) has been a vehicle for advocacy specifically for vascular surgeons. As the only voice geared for vascular surgeons in Washington, D.C., it plays an instrumental role in championing pressing concerns that matter to the wider vascular surgery community.

So what exactly does the SVS PAC do? And more importantly, why should you care? SVS PAC plays an integral role as a liaison for vascular surgeons when communicating with lawmakers on the Senate Finance, House Ways and Means, and the House Energy and Commerce committees, as well as the House and Senate Veterans Affairs Committee, and House and Senate leadership.

Aside from advocacy with various congressional committees, SVS PAC also supports congressional candidates whose positions on healthcare policies are aligned with SVS and our members. SVS support for candidates who share our views is a critical tool for achieving SVS legislative and regulatory priorities.

The PAC achieves this through monetary donations for congressional candidates—both incumbents and challengers—on a bipartisan basis.

Using a scorecard system, the committee identified members of Congress serving on congressional committees with jurisdiction over healthcare issues to cultivate for future support.

Each candidate was then evaluated on whether he or she co-sponsored or supported key SVS legislative and regulatory priorities. Visit to download the scorecard.

The following legislative efforts were taken into account in creating this scorecard, in order to hone efforts and support for politicians who advocate for patients and physicians alike:

  • Co-sponsorship of Improving Seniors’ Timely Access to Care Act of 2019 (HR 3107), legislation that reduces the burden and costs of prior authorization policies imposed by Medicare Advantage plans
  • Co-sponsorship of Resident Physician Shortage Act (HR 1763/S 348), legislation addressing the doctor shortage by adding 15,000 additional Medicare-supported residency slots over five years
  • Co-signing onto four separate congressional letters addressing the Medicare Physician Fee Schedule (MPFS) and the payment cuts to vascular surgeons in 2019 and 2020

It is through these systematic and exhaustive methods that SVS PAC gets results. In 2018 alone, we saved over $100 million in vascular ultrasound reimbursements due to successful Society advocacy supported by the political action committee.

At no time has the SVS PAC been more relevant than at this juncture. In this election year, U.S. health legislation and payment models are at a precipice. In the coming months there are proposed Medicare payment cuts ranging from 7–10%.

As we all know too well, if these cuts pass, private insurance companies will follow suit, ultimately leading to decreased payment for vascular surgery services all across the country.

This will undoubtedly affect all of us, regardless of practice patterns, geography or years in practice. The SVS PAC stands as the single strongest advocate against these myopic and unfair payment cuts. It is a proponent, not only of the member vascular surgeons but also the specialty itself and the utility it provides in health systems across the country

The time is now! Donate to the SVS PAC today. Please go to to make a contribution and to fight these cuts.

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