You have demonstrated that you do not understand how this works, so I will demonstrate this for you and anyone who wants to read this: When CMS creates the fee schedule, there are 3 components to each code: -wRVU -peRVU -mpRVU Additionally, each code has a facility payment for services rendered in ASCs or hospitals (what CMS defined as facilities). The peRVU number for any given code is higher in a facility than it is in a physician office, since overhead such as staffing and equipment is payed by the facility via facility fees. Global payment for services in an office (which is the combined payment of all those 3 RVU factors above) tends to be much higher than the payment to a physician in a facility since the physician is responsible for using that money to cover overhead. The problem is that the money for physician services (the PFS) is declining each year. The money spent on facility fees is increasing each year. We have now reached a point where independent practice is becoming unsustainable which is reflected in the mere fact that 80% of physicians are now employed. Why is this? Multi factorial but the main reason is that declining PFS payments are not enough to cover the expenses of running a practice. In fact, within my world of the endovascular space, we have 195 CPT codes paid at rates less than their direct costs. Facilities are paid rates much greater than what we are paid for rendering the same service in an office. Here’s a nice example. Let’s pick IVC filter placement, CPT 37191 -payment in an office: $1938.21 -payment to a hospital: $5241.36 -payment to physician if done in a hospital: $210.19 If the product device costs $1500, my labor in an office is approximately $200/hour and the entire service from start to finish including recovery takes 1 hour, how do I make any money? We’re not even factoring malpractice, rent, insurance, capital expenses including ultrasound, c-arms and more. This isn’t propaganda. This is simple math and CMS national average data. Now play this out where expenses including labor expenses and supply costs are going up every year but that global payment in the office is going down. Not sustainable.