CMS Enforcement Update
CMS Enforcement Update: Are Your Vascular and Primary Care Practices Ready?
Earlier in May 2026, the CMS enforcement update flagged concerns about office-based vascular procedures. It was discovered that about $105 million of Medicare Part B spending in 2023 may have been medically unnecessary. The report was sent to CMS, which then asked auditors to follow up.
Now, recovery audit contractors (RACs) are checking selective catheter placement procedures. This directly affects vascular surgeons, interventional cardiologists, interventional radiologists, and even primary care doctors who refer patients.
What the Report Found
The report looked at Medicare payments for angioplasty, stenting, and atherectomy for artery disease. More procedures are being done in office-based labs (OBLs), which pay more than hospital outpatient departments.
Additionally, 139 physicians were flagged for unusual billing patterns. About 26 of them were responsible for 61% of the payments flagged – with an average of about $3 million each. The report also noted that some of the procedures were clinically controversial, meaning they have higher risks and are sometimes unnecessary. It is important to note that the OIG did not say these doctors committed fraud, but only said the billing patterns needed closer review.
Why This Matters for Other Doctors
If a practice was not flagged, similar billing patterns like these may trigger audits. It is crucial for primary care doctors as well to pay closer attention. Patients with peripheral artery disease or diabetes are likely to show up in primary care first, and records from these visits can be important if procedures are later audited.
How to Prepare
- Document everything: Remember to show that conservative treatments, like medication, exercise, or lifestyle changes, were tried before the procedure.
- Check procedure details: Ensure reports and images support the procedure for selective catheter placement (CPT 36247) and tibial interventions (CPT 37229)
- Review billing patterns: Compare procedure volume and mix to peer benchmarks to see if anything looks unusual.
- Train staff and review policies: Internal compliance can reduce risk and it also shows the auditors that the practice is careful.
Takeaway
Vascular procedures are being constantly reviewed by CMS and RAC auditors. Practices must ensure all records are accurate and complete. Clear documentation, proper coding, and internal compliance programs are essential to avoid problems.
