The One Negative Row in Medicare's New Dialysis Rate Book

CMS puts an impact table at the back of every rate book, and the point of it is reassurance. Thirty rows, an average on the top line, and the average is what gets quoted.

This one has a row that reads -2.9%.

The CY2027 End-Stage Renal Disease final rule, CMS-1846-F, went on public inspection at 4:15pm ET this afternoon, and the PDF's own Last-Modified header puts the filing at 20:15:10 UTC.

We wrote this morning that the rule's RIN had come off OMB's pending review list with nothing yet at the far end.

It took nine hours.

"Who is actually down on a rule CMS scores as a 2.7 percent raise?"

The Raise Is $2.83

The headline is a 2.7 percent increase, about $240 million across 7,570 facilities and 24.0 million treatments. $50 million of it is beneficiary coinsurance.

The base rate goes from $281.71 to $297.52, and CMS prints the arithmetic: (($281.71 + $12.85) x 1.00260 x 0.98864) x 1.019 = $297.52.

Run that same expression with the phosphate binder term zeroed and you get $284.54.

So of the $15.81 increase, $12.98 is phosphate binders moving out of the TDAPA and into the bundle, and $2.83 is the actual rate update. That is 1.0 percent against a 1.9 percent update, because the budget neutrality factor of 0.98864 takes the rest back.

The 1.9 is itself a rebased ESRDB market basket of 2.9 percent less a 1.0 point productivity adjustment.

Commenters caught this on the proposed rule. The final base rate came in $2.03 lower than the proposed $299.55 anyway, even though the market basket update went up from 1.6 to 1.9 percent, because the phosphate binder addition fell from $15.96 to $12.85.