Payment Stability for Dialysis Vascular Access Centers of Excellence
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.
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) in 2018 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 the 2018 Ambulatory Surgical Centers (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.
Unfortunately, the 2024 Physician Fee Schedule proposed yet another round of huge cuts to the same key vascular access code that was cut by 39% in 2017 and will cause another round of center closures and further threaten access to dialysis vascular access care.
In 2017 payments to a key vascular access code were cut by 39%
More than 20% of respondents surveyed stated their centers had closed due to the cuts
Medicare claims data has confirmed a decrease in office-based vascular access services of more than 30% since 2017
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 Congress stop the clinical labor policy contained in the 2024 Physician Fee Schedule (PFS) Proposed Rule and instead work on fundamental reform of the PFS to ensure that providers do not experience drastic swings in payments year to year.
Read DVAC’s letter to the Centers for Medicare and Medicaid Services on the CY 2024 Ambulatory Surgical Center (ASC) 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 2021 ASC Fee Schedule, CMS finalized a transition of 1,700 services from the Inpatient Only (IPO) list over the following three years, which had the potential to significantly disrupt APCs, including the APC containing key dialysis vascular access codes. While we were encouraged CMS halted the elimination of the IPO list in the 2022 ASC Fee Schedule, we remain concerned about the integrity of the current APC structure given the history of volatility in ASC rates for dialysis vascular access.
We are encouraged that CMS is now undertaking a review of complexity adjustment combinations under the ASC for dialysis vascular access codes and we urge CMS to continue this review of complexity code adjustments in future rulemaking.
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.