Downcoded

Who Is Paying for the Dialysis Raise?

CMS proposes a $17.84 increase to the ESRD base rate for CY2027. Phosphate binders account for $16.06 of it, and a rebuilt low-volume adjustment charges every facility above 8,000 treatments $3.34 a treatment to fund the ones below. Comments close August 24.


Medicare's dialysis base rate goes up $17.84 next year, from $281.71 to $299.55.

That is a 6.3% increase in a payment system whose statutory update for the year is 1.6%, and it is the number that gets printed.

Then you read the arithmetic CMS printed next to it.

"How much of a six percent raise is actually new money?"

CMS-1846-P, the CY2027 ESRD PPS proposed rule, hit the Federal Register on June 26 at 91 FR 38784, and comments close August 24.

Two moves inside it decide what a dialysis facility collects in 2027, and neither one is the base rate.

The Pill Inside the Base Rate

CMS prints its own build, in order: (($281.71 + $15.96) x 1.00267 x 0.98783) x 1.016 = $299.55.

The $15.96 is phosphate binders.

Oral binders have been riding the TDAPA since January 2025, and that period ends. For CY2027 CMS proposes to fold the drug into the bundle permanently, at an amount derived from $269,634,395.87 of direct drug spend between April 1 and December 31 of 2025, marked up 6% for operational cost to $285,812,459.62, spread across 17,733,591 paid hemodialysis-equivalent treatments, then trimmed 1% for the outlier pool. That is $16.12, then $15.96.

The $15.96 goes in ahead of the multipliers, so it carries $16.06 of the final $17.84 (chart below). Everything that is not a phosphate binder adds $1.78, or 0.63%, to a rate that has to cover nursing, machines, water treatment, and every other drug in the bundle.

Money that was already flowing through the TDAPA, moved into a different column. Your CY2027 rate sheet looks 6.3% better and your CY2027 revenue does not.

The rest of this brief is for subscribers.

The impact tables, the code-level detail, and the rest of the analysis sit past this line.

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