The following is an email blast that was shared with members end of last week PFS:

The 2018 Proposed Physician Fee Schedule was released last week. The dialysis access procedure codes 36901 – 36909 are proposed to have essentially the same physician work and practice expense RVUs as in 2017. ASDIN has been working with a coalition that includes the RPA and industry partners to ask CMS to increase the assigned RVUs to at least the level that was recommended by the RUC last year. Unfortunately, they did not include an increase in the proposed rule. On a positive note, CMS did invite comments specifically on these codes asking for input about whether the complexity and severity of illness of the typical patient was adequately represented in the RUC process. This is an indicator that they could be open to making changes in the final rule and ASDIN will be commenting to provide them with information to that end. The ASC proposed rule was also released and the valuation of these codes 36901 – 36909 is also essentially the same as in 2017. This is good news for those members whose access center is an ASC because the valuation in that site of service improved significantly in 2017. ASDIN’s comments to CMS about the proposed rules will be available once they are submitted in the coming weeks.

Tim Pflederer
ASDIN Public Policy Committee