SVU Advocacy Submits Comments on CMS 2027 Proposed Payment Rules

Dear SVU Members,

The SVU Advocacy Committee worked with our legislative counsel- Elizabeth Hardcastle Esq. and George Maliha MD of Sidley Austin LLP, to review the 2027 Proposed Rules from the Centers for Medicare and Medicaid (CMS) and provide comments. I am sure you will find our comments to be concise and complete- supporting our members and the work we do. As Elizabeth noted to our committee, we efficiently addressed several areas of concern.  

As a reminder, OPPS-the Outpatient Prospective Payment System and PFS- the Physician Fee Schedule- govern Medicare payments at different sites of service. OPPS addresses hospital outpatient departments and similar facility settings, and PFS governs payments for services provided by physicians and other practitioners across various practice settings. CMS proposed rules for both and SVU responded in two separate comments. Additionally, we invited SVS to review our comments before submission to assure collaboration and not conflict. We are always grateful for their insight and input. Because Sidley Austin provided such a concise summary of our process, I am taking the liberty of sharing it with our members. The Comment Letters will be published on the SVU Website. This is yet another example of your Advocacy Committee looking out for you!  

A brief summery from Sidley Austin: 

1. In the OPPS Letter, the focus was on (1) SVU’s codes, (2) the site neutrality proposal, and (3) a drop in 340B drug reimbursement that harms many hospitals where SVU members work. 
   • Generally, SVU and SVS agreed with the analysis of codes, but in SVU’s calculation of the reimbursement drop, we used the OPPS cap to the PFS.  Because the PFS actually caps imaging technical components by the OPPS rate, a few of SVU’s codes of interest are affected. 
   • Because CMS did not have any specific comment solicitation this year, SVU did drop our yearly discussion about valuing carotid Doppler like echocardiogram. But we will always readdress the issue as often as possible. 
2. In the PFS, our SVU comments focused on (1) codes experiencing reimbursement drops (some trans-cranial Doppler, penile ultrasound, and AAA screening) and (2) changes to reimbursement that benefited vascular surgery. 
   • Finally, we did drop our yearly discussion on clinical labor rate values; CMS has finalized its proposal for several years now and was not focused on that this year. 

Hopefully, the summary from Sidley Austin will provide some background for the Comment Letters submitted on August 31, 2026, to CMS.  

Any questions, concerns or comments may be submitted to me at annejones414@gmail.com and, if necessary, I will share them with Elizabeth Hardcastle and George Maliha. 

Sincerely, 

Anne M. Jones BSN RVT RDMS FSVU 
Advocacy Chair
Society for Vascular Ultrasound
annejones414@gmail.com

Resources:

• SVU Comments to HOPPS 2027 Proposed Rule
• SVU Comments to PFS on Proposed Rules