The 2022 Medicare Physician Fee Schedule (PFS) final rule issued on November 2, 2021 cuts a broad array of office-based specialists as a result of so-called “budget-neutral” effects of the CMS policy to update clinical labor data in the PFS.  These cuts, which are phased-in from 2022 through 2025, will continue to accelerate the health system consolidation trend and exacerbate health inequities in a variety of diseases. 

The table below describes all specialties cut more than 5% in the 2021 PFS Rule, although the final rule phases many of these cuts in over four years.  It is important to note that the impact table below taken from the 2022 PFS Final Rule does not disaggregate specialty impact by site-of-service and, as a result, masks the true (even worse) impact to the office-based setting.  

On top of these cuts are the phased-in impact of the 2021 EM cuts which, as a result of the Consolidated Appropriations Act of 2021 and subsequent legislation, resulted in a 3% cut to the PFS conversion factor occurring in 2021, a 0.75% cut to the PFS conversion factor on January 1, 2022, an upcoming 3% cut to the PFS conversion factor on January 1, 2023, and another 3% cut to the conversion factor slated for January 1, 2024.