Coding and Reimbursement Impact on Dialysis Access Care
Reimbursement for dialysis care has been under scrutiny by CMS for some time. Specifically, in 2017 CMS created new bundled service codes for maintenance and repair of dialysis vascular access (codes 36901-36908) after scheduled review of high-volume services. Since the implementation, these codes have made a significant impact on the industry in terms of reimbursement relative to the place of service in which these procedures are performed.
Ambulatory Surgical Centers (ASCs) saw a dramatic rise in dialysis services compared to those performed in extension of practice (EOP) physician office surgery centers. In response to this, CMS did propose changes to reimbursement for 2019 to neutralize the shifts in practice patterns per setting, but these were not finalized. The proposal would have reduced reimbursement for dialysis procedures in the ASC by applying the rate assigned under the Medicare Physician Fee Schedule (MPFS) and used for the EOP rather than the assigned ASC rate.
In July 2019, CMS released a proposed mandatory alternative payment model for 2020 specific to dialysis procedures for end stage renal disease (ESRD) and kidney transplants. The push is for more of these procedures to be treated and addressed with home care. The fact sheet for this proposed rule can be found at https://www.cms.gov/newsroom/fact-sheets/proposed-end-stage-renal-disease-treatment-choices-etc-mandatory-model. CMS has yet to release the 2020 proposed rules for MPFS and Hospital Outpatient Prospective Payment System (HOPPS) which includes ASCs. It is possible CMS will address dialysis services again in the outpatient setting due to the other recent proposed ruling. Stay tuned for more information.
