Our Priorities

Payment Stability for Dialysis Vascular Access Centers of Excellence

DVAC’s Mission is to:

Ensure Payment Stability for Vascular Access Centers of Excellence
Reduce Catheter Rates in Dialysis Patients

While non-hospital specialization is positive for Medicare beneficiaries and total program costs, it also makes such providers vulnerable to significant volatility in reimbursement rates, given that such providers do not broadly diversify their services as a typical hospital might. As a result, unlike hospitals, significant payment volatility for vascular access centers cannot be offset by increases to other services in Medicare fee schedules.

The correlation between reimbursement pressures facing non-hospital dialysis vascular access and the rise in catheter rates is explicitly noted in the 2025 USRDS report as follows:

[T]he Centers for Medicare & Medicaid Services (CMS) reduced reimbursement for vascular access procedures performed in outpatient vascular access centers in 2017 through a change in the Medicare Part B Physician Fee Schedule. Reimbursement, which was cut by nearly 40% for some procedures, led to closure of more than 20% of vascular access centers in 2018, according to a survey by the Dialysis Vascular Access Coalition (Dialysis Vascular Access Coalition, 2021; Litchfield, 2019). This wave of closures, which likely limited capacity to perform vascular access procedures, presumably contributed to the increased percentage of patients initiating HD with a catheter alone from 2017 to 2022. Several years later, however – and seemingly at odds with the reduction in the Medicare Part B Physician Fee Schedule for outpatient vascular access procedures – CMS initiated the Kidney Care Choices (Jain & Weiner, 2021) a value-based care payment model that incentivizes an “optimal start” to treatment of kidney failure.

Physician Fee Schedule

DVAC strongly supports the 2026 Medicare Physician Fee Schedule as the first CMS regulation in recent years that recognizes the plight of dialysis vascular access providers. We urge CMS and Congress to continue to build on the foundational changes in the 2026 Medicare Physician Fee Schedule by enacting legislation to reform the PFS to its original intent: paying for the work of physicians and allied professionals, rather than medical supplies and equipment.

Read DVAC’s letter to the Centers for Medicare and Medicaid Services on the CY 2026 Physician Fee Schedule (PPS) Proposed Rule.

ASC Fee Schedule

Like the Physician Fee Schedule, dialysis vascular access under the ASC Fee Schedule has been subject to significant volatility in recent years.

In 2018 and 2019, changes to the office-based designation policy and the device-intensive classifications resulted in proposed payment cuts to key dialysis vascular access codes of roughly 62% and 20%, respectively (click here for further information). Fortunately, these policies were never finalized.

In the 2018 Hospital Outpatient Prospective Payment System, CMS considered stakeholder suggestions to expand the current endovascular APC family to a 5 or 6 APC family. Given new endovascular codes sets, policies in the 2026 HOPPS Final Rule to eliminate the inpatient only (IPO) list over a 3 year period, and efforts to add additional procedures to the ASC Covered Procedures List (CPL), future rulemaking could disrupt the APC treatment of dialysis vascular access procedures. Given these trends, DVAC intends to study the feasibility and potential benefits of a new dialysis vascular access APC that would provide additional reimbursement stability to these services over time.

Read DVAC’s letter to the Centers for Medicare and Medicaid Services on the CY 2026 Ambulatory Surgical Center (ASC) Proposed Rule.