Vascular Access Centers (“VACs”) are outpatient facilities that specialize in access maintenance for patients with end stage renal disease (“ESRD”).
ESRD patients that develop vascular access problems as a result of dialysis, such as prolonged bleeding, inadequate blood flow, or increased venous pressure may require treatment in a VAC. Approximately 80.3% of ESRD dialysis patients are treated via catheter, and as a result VACs also play a critical role in reducing the hospitalization of ESRD patients by allowing non-emergency interventional procedures to be performed in an outpatient setting. For patients who do not have ESRD, VACs may offer an alternative setting for other interventional vascular procedures including access for medical oncology, Peripheral Arterial Disease (“PAD”), and enteral nutritional and medicine delivery, among others.
A vascular access center is frequently operated under an Extension of Practice (“EOP”) model whereby procedures are performed and billed as an in-office ancillary service of the physician practice and reimbursed under the Medicare Physician Fees Schedule (“MPFS”). Beginning January 1, 2017, changes in the MPFS resulted in significant reimbursement cuts for several commonly performed vascular access procedures, and as a result, a vascular access center operated under the EOP model will see profits decline significantly. As shown in the table below, the bundling of certain CPT codes and reductions in the fee schedule reduced reimbursement for certain VAC procedures by as much as 47%.