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After a 39% cut in 2018, payment for dialysis access procedures will remain stable next year
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Plans by CMS to bundle codes for vascular access procedures, set to take effect in January, have been shelved after opposition from vascular access groups and members of Congress.
CMS released the final rules last month for the Hospital Outpatient Prospective Payment System/Ambulatory Surgery Center Payment System, which covers payment codes for access procedures done in outpatient settings.
The proposed changes would have designated CPT codes 36902 and 36905 as office-based, which would have resulted in major cuts in vascular access payments. CMS wrote in the final rule that it would retain the two codes under G2, the current payment indicator. No other coding changes were proposed.
“CMS reversed a proposal to apply site neutral payments to the two highest volume dialysis circuit (vascular access) procedure codes, thus reversing proposed cuts of over 54% for the two services,” wrote Robert Blaser, director of public policy for the Renal Physicians Association in a recent edition of RPA News. “These would have been devastating reductions for nephrology practices with arrangements to provide vascular access services under the ASC designation.”
The Dialysis Vascular Access Coalition (DVAC), a consortium of medical specialty societies, physicians and non-hospital centers that provide vascular access services to dialysis patients, said the code changes, if implemented, could have “lead to an inappropriate migration of services from a cost-effective non-hospital setting to a costlier hospital setting.” The outpatient access industry took a 39% cut in payments in 2018 after CMS bundled procedures under revised codes. “Medicare payment reductions to the ambulatory surgical center and physician office settings are already beginning to turn the clock back on vascular access services for ESRD patients,” the coalition wrote in a Sept. 17 letter to CMS Administrator Seema Verna responding to proposed changes for 2019. “Survey data provided by the American Society of Diagnostic and Interventional Nephrology (ASDIN) make clear that the payment reductions to the physician office setting already have caused significant numbers of physician office closures. The payment reductions in the CY 2019 ASC Proposed Rule threaten the ASC site-of-service as well, which will drive still more patients back into the hospital for care.”
On Oct. 11, a group of 27 members of the U.S. House of Representatives submitted a letter to HHS Secretary Alex Azar expressing concerns about the proposed coding changes.
“If HHS finalizes this policy shift, patients will be impacted with respect to accessing vascular access services in the setting of their choice, receiving the appropriate level of high-quality care based on their needs and failing to maximize the most cost-effective care,” Rep. Ryan A. Costello, R-PA, and other lawmakers wrote.
The legislators also noted in their letter that the payment rate for access services in ASCs is “an important guard” against the migration of outpatient procedures to the hospital setting, where costs to Medicare are higher. “By lumping the different levels of care – doctor’s office and ambulatory surgical centers – and setting this combined rate at the low end, CMS disincentivizes higher level care being provided in the most appropriate, and cost-effective setting,” they wrote.
References:
dialysisvascularaccess.org/wp-content/uploads/2018/10/DVAC-ASC-Letter-vFinal4.pdf