Implementation of the Medicare Fee Schedule (MFS) introduced concerns about the potential for reduced access to care, especially for vulnerable populations. These analyses show differences in access before and after the MFS that cannot be explained by health status. In particular, those without private or public supplementary insurance, those with low incomes, African Americans, and the oldest old had lower utilization before the MFS. The impact after implementation of the MFS on vulnerable populations was similar, for the most part, to that for other beneficiaries: reduced utilization in areas with fee increases and increased utilization in areas with fee decreases. An exception was that African Americans, those without supplemental insurance, and those with low incomes in areas of fee decrease saw reductions in the use of surgical services relative to their counterparts in areas with no fee change.