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News & Press

DVAC Submits Comment Letter Asking CMS To Stop “Historic” Cuts

September 9, 2022

WASHINGTON, DC — Earlier this week, the Dialysis Vascular Access Coalition (DVAC) sent a comment letter to the Centers for Medicare and Medicaid Services (CMS) on the proposed changes to the 2023 Physician Fee Schedule (CMS-1770-P).

The DVAC comment letter stresses that the repeated cuts to office-based specialists under the Physician Fee Schedule are contributing to office-based center closures, health system consolidation and, as a result, are undermining the Biden administration’s efforts to address health equity issues.


In the letter, DVAC states, “We believe another round of office-based dialysis vascular access center closures not only would be likely to drive vascular access repair utilization lower, such closures also would begin to drive utilization back to the hospital. Not only would such a result obviously cost Medicare patients and the Medicare program much more, but it would also further undermine patient outcomes given that peer reviewed data has shown that patients who receive vascular access care in the office have better outcomes than those patients treated in the hospital outpatient setting.

It continues, “The 2023 PFS Proposed Rule continues these historical cuts to office-based specialists by reducing the 2023 Medicare conversion factor by about 4.5% from $34.6062 to $33.0775.”

Dr. Dean Preddie, DVAC’s policy chair, said, “As drafted, this rule will reduce patient options for life-saving care because vascular access centers will be forced to close due to insufficient reimbursement levels. We’ve already seen this horror movie and we know how it ends. DVAC is asking Congress to work with CMS on fundamental reforms and to drop these new cuts to the MPFS.” 

DVAC is a coalition of entities that provide vascular access services to individuals with advanced kidney disease and End-Stage Renal Disease (ESRD).

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