Connecticut Health Law

Earlier this year, the Centers for Medicare and Medicaid Services (CMS) confirmed that, effective January 1, 2025, CMS will pay for acute kidney injury (AKI) renal dialysis treatments at-home at the daily rate based on hemodialysis-equivalent treatments (See “ESRD & Acute Kidney Injury Dialysis: CY 2025 Updates”).  This is a tremendous advancement for the quality of patient care and a new opportunity for end-stage renal disease (ESRD) providers.

On July 24, 2025, CMS published a reminder to dialysis providers that their billing staff should be made aware of the new billing home dialysis modalities for Medicare patients with AKI:

• CMS allows providers to bill revenue codes 084X for continuous ambulatory peritoneal dialysis (CAPD) or 85X for continuous cycling peritoneal dialysis (CCPD), as applicable to AKI patients.
• Providers must use condition code 84 for AKI and a secondary condition code to indicate the site of care.
• ESRD facilities billing for AKI dialysis treatments must include both condition codes 74 and 84 on home AKI dialysis claims.
• CMS also permits ESRD facilities to bill Medicare for the home and self-dialysis training add-on payment adjustment for patients with AKI. To do so, ESRD facilities billing for training or re-training for AKI home and self-dialysis must include condition code 84 as well as either 73 or 87, as appropriate.

CMS also clarified that it is not making any changes to the use of revenue codes 082X, 083X, or 881 for AKI patients, so ESRD facilities may continue to use revenue codes 082X, 083X, 084X, 085X, or 881 when billing for AKI patients. They should bill any of these codes with condition code 84 to indicate AKI and the appropriate second condition code (73, 74, or 87) to indicate the site of care.

For additional questions about home care dialysis and any regulations applicable to dialysis providers, please contact Pullman & Comley Health Care attorneys Isabelle Bibet-Kalinyak or Stephen Cowherd.