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News & Press

DVAC Submits Comment Letter Blasting Proposed Cuts to Vascular Access

September 20, 2023

Washington, DC — The Dialysis Vascular Access Coalition (DVAC) submitted a comment letter to Chiquita Brooks-LaSure, the Administrator of the Centers for Medicare and Medicaid Services. DVAC continued to oppose the cuts contained in the 2024 Medicare Physician Fee Schedule (MPFS) released in July by the Centers for Medicare & Medicaid Services (CMS).

Read the Comment Letter:

DVAC CY 2024 PFS Proposed Rule Comment Letter (CMS-1784-P) (1)
Download PDF • 772KB

The DVAC makes the following request: “In the 2024 PFS Proposed Rule, CMS states continued interest in promoting “stability and predictability” in the PFS. We believe it would be best for CMS to truly “prioritize stability and predictability over ongoing updates” by temporarily freezing the implementation of further policy updates – including the clinical labor policy in 2024 through 2025 and the implementation of G2211 in 2024 – that will result in further cuts to dialysis vascular access centers. Instead, we urge CMS to focus on fundamental PFS reform.”

The letter highlights a multi-societal survey distributed across multiple specialties, including vascular surgery, interventional radiology, and interventional cardiology, to predominately non-hospital physicians that found:

  • 87% of respondents “believe Medicare cuts have a moderate or greater impact on the practice,”

  • 53% of respondents “believe the likelihood of the practice’s success is unlikely,”

  • 22% of respondents “are likely to become a hospital employee if cuts continue,”

  • 21% of respondents “are likely to sell their practice if cuts continue,”

  • 17% of respondents “are likely to retire if cuts continue,” and

  • 8% of respondents “retired, sold, or closed their practice from 2021 to 2022.”


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