On March 8, RPA sentrecommendations to CMS as the Agency continues its policy development process for the 2020 Ambulatory Surgical Center (ASC) proposed rule. RPA's letter calls on CMS to promote stability for vascular access services provided to Medicare ESRD beneficiaries by maintaining the current four-level structure for endovascular ambulatory payment classifications (APCs), and by keeping services with similar resource and cost requirements wit hin the same APC. The proposed rule for the 2020 ASC payment system is expected to be released in late June or early July.