Washington, DC — On August 31, the Dialysis Vascular Access Coalition (DVAC) submitted a comment letter to the Centers for Medicare & Medicaid Services (CMS) on the CY 2027 Ambulatory Surgical Center (ASC) Prospective Payment Proposed Rule. In its letter, DVAC, a coalition of societies and provider organizations representing the majority of the non-hospital vascular access sector, warns that a proposed cut to the ASC weight scaler, from 0.872 in 2026 to 0.809 in 2027, would reduce ASC payment for key dialysis vascular access services even as the same services see significant increases in the hospital outpatient setting.

Under the proposal, the key dialysis vascular access repair code (CPT 36902) would receive a 15% increase in hospital outpatient departments (HOPDs) but a 2% cut in ASCs, while vascular access creation codes would rise 12% to 14% in HOPDs and largely fall 2% to 5% in ASCs. If finalized, these rules could reverse some of the gains that Medicare and dialysis patients have seen through the migration of vascular access services out of the hospital setting. At the same time, DVAC cites analysis by Health Management Associates finding Medicare could save up to $250 million over 10 years if we could continue to move just half of remaining HOPD vascular access creation services to ASCs, and up to $100 million if half of peritoneal dialysis catheter placements did the same.

READ THE COMMENT LETTER

DVAC CY 2027 ASC Proposed Rule Comment Letter (CMS-1850-P) • .pdf 

The letter states, in part, “DVAC notes in particular that the only codes in the dialysis vascular access repair and creation families that see increases are device-intensive (J8) services. On net, DVAC is very concerned that these policies, rather than encouraging dialysis vascular access procedures to migrate to lower cost sites-of-service, would encourage migration in the opposite direction.”

The letter goes on to say, “The coalition believes that maintaining stability for ‘standard of care’ services, such as 36902, should outweigh strict adherence to maintaining proportionality for device intensive procedures between the OPPS and ASC settings. Moreover, DVAC strongly believes that CMS policies should encourage the provision of services to Medicare beneficiaries to the lowest cost site-of-service as appropriate.”

The letter makes the following requests:

• Include device portions in the ASC weight scaler. DVAC urges CMS to make device portions subject to scaling, which CMS estimates would raise the proposed scaler from 0.809 to 0.865 and reduce the cut to 36902 and vascular access creation codes in the ASC setting.

• Encourage migration to non-hospital settings. DVAC urges CMS to support policies that encourage appropriate migration of vascular access creation and peritoneal dialysis catheter placement services to “the more cost-effective and patient preferred non-hospital (ASC and office) settings.”

• Stabilize reimbursement. DVAC asks CMS to stabilize Medicare reimbursement for non-hospital dialysis vascular access, citing a rise in the share of adult dialysis patients relying on a catheter from 16.7% to 23.7%.

• Keep the hospital market basket for ASCs. “DVAC supports CMS' continued use of the hospital market basket as the annual update mechanism for ASC payments.”

• Fix packaging and complexity adjustments. DVAC asks CMS to address longstanding concerns with packaging of add-on codes and a complexity adjustment policy whose eligible ASC code combinations have fallen from 55 in 2023 to 41 proposed for 2027.

• Approve pass-through status for EndoForce™. DVAC asks CMS to reverse its proposed denial of transitional pass-through payment status for the EndoForce™ System, which DVAC believes has the potential to reduce catheter dependence and improve graft patency.