Washington, DC — This week, the Office-Based Facility Association (OBFA) submitted official comments to the Centers for Medicare and Medicaid Services (CMS) on the proposed rule for the CY 2025 (CMS–1807–P). .

The OBFA letter, addressed to CMS Administrator Brooks-LaSure, stressed that the Proposed Rule would impose yet another round of significant cuts to office-based interventionalists, and how the rule would exacerbate provider deserts.

Furthermore, it underscores the disturbing data that shows CMS will not pay clinicians in private practice enough to cover the direct expenses of those services before even considering other costs like physician work and indirect costs. The OBFA is asking CMS to remove certain high-cost supplies and equipment from the PFS in order to protect patient access.

The letter points out that, “All of these services are procedures performed outside of the hospital in the patient-preferred, community-based setting and that these services typically are the lowest cost option available to Medicare beneficiaries.”

The letter goes on to state that: “In 2019, the average payment for these same 300 codes reimbursed 43% more when performed in an outpatient hospital setting compared to an office setting. By 2024, this disparity had ballooned to 124% on average. As reimbursements for high-technology procedures decrease in the office setting, the same services provided in the hospital show significant increases. This dynamic further drives hospital consolidation and reduces the number of specialists in lower cost settings.”

READ THE COMMENT LETTER ON (CMS–1807–P) :