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News & Press

Dialysis Vascular Access Coalition Submits Comment Letter Opposing Clinical Labor Policy
DVAC opposes proposed 20% Medicare Cut to Dialysis Vascular Access Services

September 15, 2021

CONTACT: Grant Herring

(202) 552-1708‬

WASHINGTON, DC — Today, the Dialysis Vascular Access Coalition (DVAC) announced that it submitted a comment letter to the Centers for Medicare and Medicaid Services (CMS) on the proposed rule for the CY 2022 Physician Fee Schedule (CMS–1751–P).


In the letter, DVAC strongly opposes the implementation of the clinical labor policy and the proposed cuts to vascular access services. The letter spells out how cuts to office-based specialists will exacerbate health inequities and system-wide consolidation. 

Each year, Vascular Access Centers treat more than half of a million cases in the United States in a safe, patient-preferred setting and the proposed cut of 20% will force many of these centers to close.

The letter to Chiquita Brooks-LaSure, the Administrator of the Centers for Medicare and Medicaid Services (CMS), stated, “The second- order negative effects of PFS “budget neutrality” greatly outweigh incorporating new clinical labor data, we strongly recommend CMS not finalize the clinical labor policy at this time in the 2022 PFS Final Rule.”

The letter continued, “Given the strong correlation between ongoing cuts and reimbursement volatility for PFS providers vis-à-vis the health system consolidation trend, we believe the best characterization of the so-called PFS “budget neutrality” provision is that it is a driver of PFS center closures and increased costs to the Medicare program. “

Dr. Gregg Miller, DVAC Health Policy Chair, said, “These proposed cuts from CMS set off a chain reaction. They will force vascular access providers to go out of business, leave patients with fewer options, widen the health equity gap, further disadvantage people of color, and drive up Medicare spending. We urge CMS to work with Congress on fundamental reforms to the PFS and not implement the clinical labor policy at this time.” 

Miller continued, “While the nation is still grappling with the pandemic, we must make sure office-based interventions are viable so hospitals can focus on COVID-19 patients. Now is not the time to squeeze office-based providers out of the system.” 

DVAC is a coalition of entities that provide vascular access services to individuals with advanced kidney disease and End-Stage Renal Disease (ESRD). DVAC represents specialty societies and the majority of the non-hospital vascular access sector. To learn more about DVAC and its mission, visit

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