Key Updates in ESRD Regulations: What Dialysis Centers Need to Know
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CMS issued its final rule on November 20, 2025, updating payment rates and policies under the End Stage Renal Disease (ESRD) Prospective Payment System (PPS) for services furnished on or after January 1, 2026. The rule increases overall ESRD reimbursement while reducing reporting burden and ending the ESRD Treatment Choices Model.
A healthcare law firm can help translate CMS’s regulatory updates into clear, practical guidance. They help by explaining what has changed, identifying compliance risks, and advising on reimbursement strategies. So providers can move forward with confidence and avoid costly missteps under the updated ESRD payment framework.
Payment Updates
CMS finalized several payment changes for the ESRD PPS in 2026. These changes are intended to account for cost trends and ensure continued access to dialysis services across care settings.
- ESRD PPS base rate increased to $281.71, up from $273.82 in 2025.
- CMS projects a 2.2% overall payment increase to ESRD facilities in 2026.
- AKI dialysis payment rate is also set at $281.71, with wage index adjustments applied.
Geographic and Wage Adjustments
To better reflect regional cost differences, CMS finalized targeted geographic payment adjustments, particularly for areas with higher non-labor expenses. These updates are intended to improve payment accuracy while maintaining stability through continued wage index protections.
- CMS finalized a new payment adjustment for non-contiguous areas to address higher non-labor costs:
- Alaska and U.S. Pacific Territories: 25% increase
- Hawaii: 21% increase
- Routine updates to the ESRD-specific wage index continue, including the 0.6000 floor and 5% cap on decreases.
Outlier Policy Changes
CMS also finalized revisions to the ESRD outlier policy, adjusting key thresholds that determine eligibility for additional payments. These changes may affect the number of cases qualifying for outlier payments and are intended to better align payments with unusually high-cost patients.
- CMS lowered fixed dollar loss (FDL) and Medicare allowable payment (MAP) thresholds for both adult and pediatric patients, which may affect outlier eligibility.
ESRD Quality Incentive Program (QIP)
CMS finalized several updates to the ESRD Quality Incentive Program aimed at reducing administrative burden while refining patient experience measurement. These changes reflect CMS’s assessment of measure effectiveness and efforts to streamline reporting requirements without compromising quality oversight.
- Beginning with Payment Year 2027, CMS is eliminating three health equity reporting measures, citing administrative burden and limited benefit.
- The ICH CAHPS survey will be shortened to 39 questions starting in PY 2028 to improve response rates.
ESRD Treatment Choices Model
CMS finalized the early termination of the ESRD Treatment Choices (ETC) Model following an evaluation of its performance against quality and cost-saving objectives.
- CMS finalized the early termination of the ESRD Treatment Choices Model, effective December 31, 2025
Connect with a Healthcare Law Attorney
Dialysis providers should prepare for higher base payments in 2026, reassess geographic and outlier impacts, update QIP reporting processes, and plan for the end of the ETC Model. Experienced healthcare legal counsel can help providers navigate these changes with confidence, ensure compliance, and maximize reimbursement under the updated ESRD framework.
At Fenton Jurkowitz Law Group, we help healthcare providers stay compliant, protect their operations, and avoid costly missteps. Reach out through our website today to connect with a healthcare attorney who can help keep your practice on track.