September 29, 2016
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Proposed bundling in Medicare Fee Schedule could cut interventional access revenue up to 40%

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A proposal to bundle Medicare codes that set reimbursement for interventional dialysis procedures could cut revenue for access centers by up to 40%, industry officials say.

The changes are part of the proposed rule for the Medicare Physician Fee Schedule released July 7, and would become effective Jan. 1 if no changes are made. The final rule is expected around Nov. 1.

Other proposed changes to the Medicare Fee Schedule, which is updated yearly, would impact payments to nephrologists, including a proposal to re-assess whether monthly payments for visits to home dialysis patients should be the same as for in-center patients.

Code changes would hurt vascular access centers

 The most significant impact in the proposed rule is on the interventional procedures. In comments sent Aug. 22 to the Centers for Medicare & Medicaid Services interim administrator Andy Slavitt, the American Society of Diagnostic and Interventional Nephrology wrote the bundling of the CPT codes would have “severe ramifications for the care of ESRD patients moving forward.

“We are concerned that the dramatic reductions in valuation for CPT codes 369x1 through 369x7 in the Physician Fee Schedule (PFS) proposed rule for 2017 would, if finalized, severely threaten the viability of these vascular access centers and lead to both increased costs and disruption of a system of care that has been very positive for patients with kidney disease, “ wrote ASDIN president Kenneth Abelo, MD. “Ultimately, this disruption will lead to reduced patient access to timely care and overall reduction in the quality of care received.”

ASDIN public policy director Timothy A. Pflederer, MD, told NN&I that the interventional access centers “have the ability to provide care efficiently in an (ESRD Seamless Care Organization) environment. The access centers need to be part of the fabric of any integrated care approach. ESCOs could not be success without a seamless access care. We have broadly made that argument to CMS.” The ESCOs are part of a demonstration project launched by CMS last year to determine whether integrated care approaches will improve outcomes and reduces the costs of the ESRD Program.

Abelo agrees, arguing in the group’s comments that interventional centers have helped to save the Medicare program from paying higher costs for hospital care when a dialysis patient needs an access repair or creation.

“If the 2017 proposed work and PE RVUs are implemented many outpatient access centers that focus on providing care for ESRD patients may no longer be able to operate,” he said. “Having dedicated centers with ability to respond rapidly to immature, dysfunctional, and thrombosed accesses has been critical in improved outcomes seen in the past few years, including increased prevalent native arteriovenous fistulas, decreased catheter use, and lower inpatient hospitalization for vascular access complications.

“Migration of the Dialysis circuit family of codes 369x1 – 369x7 back to the hospital setting will greatly increase cost to the Medicare Program. We strongly urge CMS to avoid the drastic reimbursement changes that would interrupt the progress made to date and create such challenges for our patients,” he said. -by Mark Neumann

The impact of bundling CPT codes on interventional center revenue

Download the proposed rule