Washington, D.C. – The Dialysis Vascular Access Coalition (DVAC), representing leading physician societies and provider organizations dedicated to improving vascular access care for patients with advanced kidney disease and End-Stage Renal Disease (ESRD), submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the CY 2026 Physician Fee Schedule (PFS) and Ambulatory Surgical Center (ASC) proposed rules.

DVAC commended CMS for important steps toward stabilizing reimbursement for office-based and ASC providers through updates to indirect practice expense (IPE) methodology, continued alignment of ASC payment policy with hospital outpatient departments (HOPDs), and removal of outdated quality reporting measures. These changes mark long-overdue progress for non-hospital providers that play a critical role in delivering safe, cost-effective dialysis vascular access services.

Freestanding vascular access centers save lives and reduce costs.

Recent DVAC research analyzing over 930,000 patient encounters confirmed that patients treated in freestanding office-based centers and ASCs experienced lower mortality, fewer infections, and reduced catheter use compared to those treated in HOPDs. These improvements were achieved while lowering Medicare costs by more than $10,000 annually per patient.

Payment pressures are driving higher catheter rates.

Despite their proven value, reimbursement cuts have strained non-hospital vascular access providers, contributing to a 30% increase in central venous catheter (CVC) rates from 2020–2024. DVAC urged CMS to build on the 2026 proposals by ensuring long-term reimbursement stability, noting that rising catheter rates worsen patient outcomes and increase Medicare spending.

Key DVAC requests to CMS include:

• Finalizing updates to the indirect practice expense methodology to correct years of underpayment to office-based practices.

• Continuing use of the hospital market basket for ASC payment updates and exploring a dedicated dialysis vascular access APC to provide long-term stability.

• Addressing longstanding concerns with ASC packaging and complexity adjustment policies that fail to account for innovative technologies and complex patients.

• Supporting migration of high-cost supply and equipment services to OPPS/ASC payment systems rather than the PFS, to preserve office-based care access.

• Correcting flawed assumptions related to the G2211 add-on code that undervalue the PFS conversion factor by $1 billion.

• Rejecting new “efficiency adjustments” unless paired with an appropriate update to the conversion factor.

“Non-hospital vascular access providers deliver higher quality, lower cost care for some of Medicare’s most vulnerable patients,” said Jason McKitrick, Executive Director of DVAC. “We applaud CMS for recognizing the need to stabilize reimbursement, but more must be done to ensure dialysis patients continue to have timely access to life-sustaining vascular access services.”

DVAC looks forward to working with CMS and Congress to ensure policies in the final rules strengthen community-based vascular access care, reduce disparities, and protect Medicare beneficiaries living with ESRD.

About DVAC

The Dialysis Vascular Access Coalition (DVAC) is a national coalition representing physician societies and provider organizations that deliver vascular access services to patients with advanced kidney disease and ESRD. DVAC advocates for policies that preserve patient access to safe, effective, and affordable vascular access care in freestanding, non-hospital settings. Learn more at www.dialysisvascularaccess.org