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Our Priorities

Payment Stability for VAC Centers of Excellence

In the 2017 Physician Fee Schedule, the Centers for Medicare & Medicaid Services (CMS) cut payments to a key vascular access code by 39%. A survey by the American Society of Diagnostic and Interventional Nephrology (ASDIN) survey in 2017 found that reimbursement levels were so inadequate that more than 20 percent of respondents surveyed stated their centers had closed due to the cuts. More recent Medicare claims data has confirmed a decrease in office-based vascular access services of more than 30 percent since 2017.

In 2018, ASC Fee Schedule CMS proposed to cut ASC rates for vascular access services down to office-based rates, but later reversed this decision. These actual (PFS) and proposed (ASC) cuts to vascular access centers of excellence have caused major disruptions to ESRD patients.

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CMS Letter

Read DVAC's letter to the Centers for Medicare and Medicaid Services on the CY 2021 Physician Fee Schedule Proposed Rule.

39%

 

In 2017 payments to a key vascular access code were cut by 39%

20%

 

More than 20% of respondents surveyed stated their centers had closed due to the cuts

 

30%

Medicare claims data has confirmed a decrease in office-based vascular access services of more than 30% since 2017

 

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Importance of Payment Stability for Vascular Access Centers of Excellence

Because non-hospital vascular access centers are specialized centers focused on vascular access care, they cannot diversify across a broad range of services as hospitals may do. As a result, unlike hospitals, significant payment volatility for vascular access centers cannot be offset by increases to other services in Medicare fee schedules.

Physician Fee Schedule

DVAC strongly supports efforts by the United Specialists for Patient Access and other stakeholders requesting that Medicare implement guardrails within the PFS to ensure that providers do not experience drastic swings in payments year to year.

ASC Fee Schedule

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The CY 2021 OPPS/ASC Fee Schedule finalizes the transition of 1,700 services from the Inpatient Only (IPO) list over the next three years. This policy has the potential to significantly disrupt currently existing Ambulatory Payment Classifications (APCs) either through displacement of codes within an APC or wholesale restructuring of APCs. DVAC strongly encourages CMS to ensure the integrity of currently established APCs in order that vascular access centers of excellence are not harmed through this process.

Ensuring the Success of Value-Based Payment Models

Given the critical importance of good vascular access care to keeping ESRD patients healthy and out of the hospital, DVAC notes that PFS and ASC fee schedule stability is essential to the success of various kidney care models currently being rolled out by the Center for Medicare and Medicaid Innovation.

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