News & Press
DVAC Applauds CMS Final Physician Fee Schedule Rule for Strengthening Office-Based Dialysis Vascular Access Care
December 22, 2025
Washington, DC — The Dialysis Vascular Access Coalition (DVAC) today welcomed the Centers for Medicare & Medicaid Services’ (CMS) CY 2026 Physician Fee Schedule (PFS) Final Rule, citing meaningful steps that recognize the essential role of office-based dialysis vascular access providers in delivering high-quality, cost-effective care to patients with end-stage renal disease (ESRD).
“CMS has taken an important step toward stabilizing reimbursement for office-based vascular access care,” said DVAC spokesperson Terry Litchfield. “These changes acknowledge both the value of freestanding access centers and the mounting financial pressures that have threatened patient access to timely, lifesaving dialysis care.”
Key Improvements for Office-Based Providers
DVAC particularly applauds CMS for finalizing updates to the indirect practice expense (IPE) methodology, which begin to correct longstanding payment distortions that disadvantaged office-based physicians while accelerating consolidation into hospital settings. As CMS acknowledged, applying identical indirect practice expense assumptions across facility and non-facility settings no longer reflects modern practice patterns — a concern DVAC has raised for years.
For dialysis vascular access providers, these changes represent the first meaningful improvement in office-based reimbursement in nearly a decade, following cumulative cuts of 20–40 percent for many access-related procedures since 2006. These reductions have contributed to the closure of more than 20 percent of vascular access centers nationwide, particularly in rural and underserved communities.
At the same time, CMS data show a troubling 30 percent increase in central venous catheter use since 2020, a trend strongly associated with reduced access to permanent dialysis access services and worsening patient outcomes. “Payment policy and patient outcomes are inseparable,” added Terry Litchfield. “When reimbursement fails to cover the cost of care, patients suffer — through higher catheter rates, more infections, and avoidable hospitalizations.”
DVAC also welcomed CMS’s recognition of dialysis-related clinical groupings within MIPS Value Pathways and reiterated its support for the development of a Dialysis Vascular Access–specific MVP, allowing physicians across specialties to participate in meaningful, outcomes-focused quality reporting.
Ambulatory Surgical Center (ASC) Final Rule
DVAC also welcomed CMS’s CY 2026 Ambulatory Surgical Center (ASC) Final Rule, particularly the agency’s continued use of the hospital market basket update and steps to modernize ASC policies in ways that reflect advances in clinical care and patient safety. These changes help preserve access to dialysis vascular access services in specialized, non-hospital settings and support the migration of appropriate procedures to lower-cost sites of care—benefiting both patients and the Medicare program.
Protecting Patient Access and Improving Outcomes
DVAC emphasized that non-hospital vascular access centers deliver better outcomes at lower cost compared with hospital outpatient departments. Updated analyses using national Medicare data show that patients treated predominantly in freestanding outpatient centers experience:
Lower mortality
Fewer infections
Higher rates of arteriovenous fistula use
Significantly lower Medicare spending, with annual savings exceeding $10,000 per patient
Remaining Concerns and the Path Forward
While DVAC supports the direction of the CY 2026 PFS Final Rule, the coalition cautioned that additional reforms are needed to ensure long-term stability, including:
Correcting the undervaluation of the conversion factor tied to inaccurate assumptions about G2211 utilization
Addressing the Physician Fee Schedule’s inability to adequately reimburse high-cost supplies and equipment
Rejecting efficiency adjustments that further erode physician reimbursement without a corresponding update to the conversion factor
“CMS has acknowledged the problem — and taken an important step toward a solution,” said Terry Litchfield, a patient advocate and policy advisor to DVAC. “DVAC looks forward to continuing to work with CMS and Congress to ensure that dialysis patients retain access to high-quality, community-based vascular access care that saves lives and reduces costs for Medicare.”
The Dialysis Vascular Access Coalition (DVAC) is a coalition of medical societies and provider organizations dedicated to preserving patient access to high-quality dialysis vascular access care. DVAC represents the majority of the non-hospital dialysis vascular access sector and works to advance policies that improve outcomes for patients with kidney disease.
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