Washington, D.C. –– The Dialysis Vascular Access Coalition (DVAC) – a coalition of medical specialty societies, physicians, and vascular access centers of excellence (VACs) in the office and ASC setting that provide vascular access services to individuals with advanced chronic kidney disease and End-Stage Renal Disease (ESRD) – expressed grave concern regarding deep, across-the-board 20% payment cuts to revascularization services in the Centers for Medicare & Medicaid Services (CMS) proposed Physician Fee Schedule (PFS) Rule for CY2022.  The cuts are solely based on the so-called PFS “budget neutrality” provision – a misnomer of the highest order – which was also the key driver of 2021 PFS cuts and has been driving huge cuts to PFS cardiology, vascular surgery, radiation oncology, and radiology for the last decade.  PFS “budget-neutrality” also is driving health inequities, health system consolidation and higher Medicare costs and is badly in need of reform. 

Dr. Gregg Miller, DVAC Health Policy Chair, said, “The numbers do not lie. The proposed cuts from CMS will further health care inequity across the country and leave patients with fewer options for life-saving care. Each year, VACs treat more than half of a million cases in the United States in a safe, patient-preferred setting and this deep cut of 20% will force many of these centers to close.  How do we know this?  Because there was a cut of a similar order of magnitude in dialysis vascular access in 2017, which led to at least 20% of office-based centers closing their doors due to insufficient reimbursement levels.” 

Dr. Miller elaborated further, saying, “The cuts proposed by CMS will exacerbate the disturbing trend towards health care consolidation and further disadvantage people of color, as well as drive up Medicare spending.  On top of this, the COVID-19 pandemic is not yet behind us and threatens a resurgence. We learned last year how important it was to make sure office-based interventions are viable so hospitals can focus on COVID-19 patients.”  

In the 2017 PFS, CMS cut payments to a key vascular access code by 39%. Now, these same providers are on the chopping block again for an additional 20% cut, even though a 2019 report by the U.S. Department of Health and Human Services – Advancing American Kidney Health –  found that high-quality vascular access is critical to keeping dialysis patients out of the hospital. Additional closure of office-based vascular access centers also will have negative impacts on various kidney care models currently being rolled out by CMMI. 

The racial disparities related to dialysis vascular access services would be made worse should the 2022 PFS Proposed Rule go into effect. In fact, data from the National Institute of Health shows that ESRD prevalence is roughly 3.7 times greater in African Americans, 1.4 times greater in Native Americans, and 1.5 times greater in Asian Americans compared to Caucasians, with people of color who have Chronic Kidney Disease (CKD) and are not yet on dialysis being nearly four times more likely to progress to ESRD.  Furthermore, NIH found that “starting hemodialysis with a functioning vascular access remains one of the major lingering areas of racial and gender disparities in the dialysis population.”

DVAC urges in the strongest possible terms that CMS not  implement the clinical labor data update at this time as any benefits to the PFS methodology are far outweighed by the devastating impact from associated and flawed “budget-neutral” cuts on dialysis vascular access centers and the patients they serve. Instead, we urge CMS to work with the Congress on fundamental reforms to the PFS.

To learn more about DVAC and its mission, visit www.dialysisvascularaccess.org.