The American Venous Forum is committed to promoting evidence-based best practices to ensure that patients have access to the highest quality care – especially the underserved.

We believe that vigorous advocacy in venous and lymphatic disease is critical to this commitment.

The AVF is actively advocating on behalf of our members and the patients they serve.  The following are just a few of the comment letters we have submitted as the AVF or as part of a larger coalition:

• AVF, SVS, & AVLS Letter to BCBS 
• AVF Letter to CMS
• Coalition – CY 2022 Payment Policies under the Physician Fee Schedule
• Coalition – CY 2022 Payment Policies under the Physician Payment Schedule and Other Changes to Part B Payment Policies
• AVF and SVS Comment to CMS – Transvenous Pulmonary Embolectomy NCD
• AVF Supports Clinical Labor Coalition (CLC) call for Legislation to Strengthen Community and Office-Based Providers Highlighted by Energy and Commerce Health Subcommittee

July 25, 2024

As we get closer to the November election, reimbursement cuts to doctors are again on the horizon for 2025, while almost all other parts of the US healthcare system see annual Federal updates. 

As part of the Centers for Medicare & Medicaid Services (CMS) mandatory rule-making process, the proposed 2025 CMS Physician Fee Schedule has been published for comments.  All comments are due no later than September 9th to the Agency.

The proposed Fee schedule is wide-ranging regulation that covers almost all aspects of the Part B program, including physician payment policies, quality payment provisions, coverage, and new services.  AVF members may read CMS’s public announcement here: https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2025-medicare-physician-fee-schedule-proposed-rule

Key takeaways from the Proposed Rule for AVF members include:

• Conversion Factor: For 2025, CMS is proposing a Conversion Factor of $ 32.3562 compared to the current 2024 CF of $33.2875.  This is about a blanket -2.8% cut to all physician reimbursement rates.  As background, broadly, the CF x RVUs=physician payment.  In the office setting, Total Non-Facility RVUs are used to capture the costs of supplies and equipment
• Since 2025 is the fourth and final year of CMS’s Clinical Labor Update policy, cuts to office based procedural care by specific CPT code are actually above and beyond the national -2.8% cut noted above. This table shows the office-based impact of the cuts on a selection of common venous codes used by AVF members.

On the Hospital Outpatient Prospective Payment side, CMS is proposing to update  OPPS payment rates for 2025 by 2.6 percent for hospitals that meet applicable quality reporting requirements 

“The cuts to all physicians caused by the reduced 2025 Conversion Factor underscores why Congress must act to remedy our broken national reimbursement system,” noted American Venous Forum President Dr. Ruth Bush.  “While we acknowledge the requirement of Budget Neutrality, year after year cuts to specialty care are driving consolidation right now and are already curtailing access to specialty care for our Medicare seniors,” added Dr. Bush.

“As we engage with our partners, I ask our AVF members to contact your lawmaker and share how CMS’s cuts have impacted your practice,” noted Dr. Gregory Snyder, Chair of the AVF’s Healthcare Policy Committee.  “Office-based specialists have seen dramatic cuts in recent years, and we know that many specialty providers are closing or deciding to retire, unable to keep their doors open,” added Dr. Snyder.

AVF Members: Tell Congress to fix our broken doctor reimbursement system! Click the button below to write a message that will be routed to your House member and Senators.

For those of you working in the venous treatment space, you are aware of the continuing challenges in obtaining appropriate and comprehensive compensation from insurance providers.

The American Venous forum is comprised of like-minded practitioners who are facing these same challenges.

As part of our ongoing advocacy efforts, I am proud to share with you the letter that we have submitted to leadership at the U.S. Senate and House of Representatives calling on Congress to prevent the 3.37% Medicare physician payment cut on January 1, 2024.

By endorsing this alongside our colleagues, we are hopeful that our collective voices will be strong enough to persuade lawmakers of the significant disservice that these cuts will make to their constituents.

We appreciate your continued support of the American Venous Forum, and encourage you to contact your local lawmakers and continue, or increase, involvement with our organization to ensure that all of our voices are heard as we strive to improve health care in this nation.

Best personal regards,

Gregory Snyder, MD. DABR
Chairman, Health Policy Committee
American Venous Forum

Click here to read the letter.

May 7, 2023

In recent years, many physicians and non-partisan government stakeholders have expressed concerns about the failure of Medicare payments to keep up with inflation and the rising costs of running a medical practice, as well as the negative impact it could have on patient access to care.

On April 4, 2023, a bipartisan group of doctors came together in Congress to introduce H.R. 2474, the Strengthening Medicare for Patients and Providers Act.

This legislation addresses uncertainty affecting Medicare-participating physicians and will help avoid a possible physician shortage for Medicare patients. H.R. 2474 would change the physician payment rate by providing an annual Medicare physician payment update tied to inflation, as measured by the Medicare Economic Index (MEI).

The legislation was introduced by Representatives Raul Ruiz, M.D. (D-CA-25), Larry Bucshon, M.D. (R-IN-08), Ami Bera, M.D. (D-CA-06), and Mariannette Miller-Meeks, M.D. (R-IA-01). Bill text for H.R. 2474 can be found here.

Please join us in contacting your legislator to support H.R. 2474.

January 2023

Dear AVF Members,

The AVF Health Policy Committee meets monthly on your behalf to discuss issues dealing with payer policies, reimbursements, denials, and other concerns that arise from time to time. We all have had payer denials for pre-authorization and reimbursements for venous procedures. The following tool arose from our discussions.  We believe it may help you to decrease or eliminate denials by including in your documentation all of the suggested criteria required by payers. We do not have templates, as there are many EHRs, so they would have to be created in your particular EHR. The HPC hopes this guide will be of benefit to your practice.

View or download the Guidance for Ultrasound Reports and Notes to Reduce Denials.

Sincerely,

The AVF Health Policy Committee

September 2022

Dear colleagues,

With all the attention appropriately focused on Medicare (Labor update, Conversion factor, Budget neutrality, etc.), it would be easy to lose sight of Commercial Insurance varicose vein coverage policies. However, rest assured the AVF Health Policy Committee in collaboration with the SVS and AVLS continue to support our members, as you address polices and denials which are at times capricious and others systematically restrictive. Among the most egregious policy is the long standing BCBS North Carolina Policy restricting venous procedures to one vein, per leg per life. We continue to push for a change to this policy at the regional and national level. See our latest letter to BCBS. We have and will continue to be responsive to communications from our members, who receive unjust denials, or are faced with perverse policies. If this has happened to you, please post in the AVF exchange or email [email protected].

During the last year, the Health Policy Committee adopted a more proactive approach. Leveraging our powerful new tool Policy Navigator, we have up to date venous policy documents for all commercial and private payors in the US. Not only can we quickly review current policies, but we can see proposed changes and respond in time to impact policy.  The Venous Policy Navigator is available for use in your office and can greatly reduce the work required to stay on top of the rules of the road in your region. Learn more about Policy Navigator here.

The AVF Health Policy committee is committed to supporting venous practitioners in your efforts to bring high quality care to your patients and to ensure that reimbursements systems support continued access to care.  Let us know how we can help you.

Sincerely,

The AVF Health Policy Committee