Washington, DC — On September 14, the Dialysis Vascular Access Coalition (DVAC) submitted a comment letter to Centers for Medicare & Medicaid Services (CMS) on the CY 2027 Physician Fee Schedule (PFS) Proposed Rule. In its letter, DVAC, a coalition of societies and provider organizations representing the majority of the non-hospital vascular access sector, calls on CMS to stabilize Medicare reimbursement for non-hospital dialysis vascular access, warning that payment pressures on these centers have coincided with a troubling rise in catheter use among dialysis patients.

The letter presents DVAC's updated site-of-service study, which matched 82,498 Medicare beneficiaries treated at freestanding outpatient centers (FOCs) with 66,188 treated at hospital outpatient departments (HOPDs). Patients treated at FOCs had lower annual mortality (16.55% versus 18.11%), fewer infections, more arteriovenous fistulas, and fewer central venous catheters, at annual savings of roughly $10,020 per patient compared with the HOPD setting.

READ THE COMMENT LETTER

DVAC CY 2027 PFS Proposed Rule Comment Letter (CMS-1848-P) • .pdf 

DVAC's letter draws on the 2025 United States Renal Data System (USRDS) report, which links a 2017 PFS reimbursement cut of nearly 40% for some vascular access procedures to the closure of more than 20% of vascular access centers in 2018, and to an increase in patients initiating hemodialysis with a catheter alone.

The letter states, in part, “In summary, patients receiving access-related care predominantly at a FOC had greater AVF use with a lower use of CVCs, fewer infections, and a lower mortality rate than those receiving care at a HOPD. These outcomes were achieved at substantially lower cost.”

The letter goes on to say, “This worsening trend not only contributes to higher infection rates, but also costs Medicare more money. Compared to fistulas, the average annual total cost of treating patients with catheters is significantly higher ($90,000 for catheters vs. $64,000 for fistulas). Dialysis vascular access centers need Medicare payment stability to help reverse these troublesome trends in catheter rates.”

The letter makes the following requests:

• Stabilize reimbursement. DVAC asks CMS to stabilize Medicare reimbursement for non-hospital dialysis vascular access, noting that recent cuts have been at odds with initiatives such as the Kidney Care Choices model.

• Remove the indirect practice cost index. DVAC “strongly supports the CMS proposal to remove the indirect practice cost index” from the calculation of practice expense RVUs, citing current IPCI values of 0.42 for interventional radiology and 0.36 for vascular surgery.

• Use OPPS data for office-based practice expense. “Because the PFS was not built for high-cost supplies and equipment, DVAC supports the use of OPPS data to set rates for office-based practice expense and recommends working with Congress to achieve this objective.”

• Create a Dialysis Vascular Access MVP. DVAC applauds the inclusion of dialysis-related vascular access measures in the proposed Nephrology, Interventional Radiology, and Vascular Surgery MVPs, and recommends a standalone Dialysis Vascular Access MVP available to any physician who provides these services, regardless of specialty.

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