For dialysis units, this revision is a swap: minus 20 points on the base fee, plus 20 points on a capacity add-on.
Base points for J038 hemodialysis fell by a uniform 20 points across all nine categories, and a renal replacement therapy capacity add-on (20 points per day) was created. Facilities that can earn the add-on hold their previous level; only those that cannot lose money.
1. What changed
| Item | Change | Old → New | Impact |
|---|---|---|---|
| J038 hemodialysis base points reduced | Uniform ▲20 pts across all nine categories | Chronic maintenance dialysis 1: under 4 hrs 1,876 → 1,856; 4–5 hrs 2,036 → 2,016; 5+ hrs 2,171 → 2,151; "other" 1,580 → 1,560 (verify) | High |
| Renal replacement therapy capacity add-on (new) | Requires (1) disaster planning (manual plus annual drill), (2) peritoneal dialysis volume (24 home PD guidance fees per year) or transplant volume (2+ in the prior year), and (3) coordination for vascular access complications | New: 20 pts/day (verify) | High |
| Transitional measures for the add-on | Drill requirement waived through 31 May 2027; volume requirement waived through 31 May 2028 | — | Medium |
| Existing add-ons unchanged | After-hours and holiday add-on 380 pts, dialysate quality add-on 10 pts, lower-limb PAD guidance add-on 100 pts/month, initiation add-ons — all unchanged | Unchanged (verify) | Low |
| Chronic kidney disease | CKD added to eligible conditions for the community comprehensive care add-on (with care need). Chronic maintenance dialysis patients added to the remote coordination fee scope in depopulated areas | — (verify) | Medium |
2. What it means for the practice
The loss from not earning the add-on is calculable exactly. Twenty points (200 yen) per session × roughly 156 sessions per patient per year. For a 100-patient unit, that is about 3.12 million yen a year.
Three things to work through during the transitional period:
(1) Disaster planning and drills. An annual drill is required; participation in Japanese Association of Dialysis Physicians drills is an option. The drill requirement is waived through 31 May 2027.
(2) Launch a peritoneal dialysis programme, or coordinate volume with a facility that has one. Twenty-four home PD guidance fees per year is achievable by managing two patients a month. Opening a PD clinic makes sense both for the requirement and for the community need — supporting elderly patients for whom travel is difficult. Transplant volume (2+ in the prior year) is an alternative. The volume requirement is waived through 31 May 2028.
(3) Document the vascular access coordination agreement. Coordination for shunt complications is part of the requirement. Put it in writing rather than relying on a verbal understanding.
For pre-dialysis CKD, adding CKD to the community comprehensive care criteria widens billing opportunities in the primary care role. Redesign the division of labour with referring internists.
3. Practical checklist
- Is a disaster manual in place, with an annual drill planned? (transitional deadline: 31 May 2027)
- Have you decided how to meet the volume requirement — 24 PD guidance fees a year, or 2 transplants? (transitional deadline: 31 May 2028)
- Is the vascular access coordination agreement documented?
- Have you quantified the loss if the add-on is not earned?
- Have you checked community comprehensive care eligibility for pre-dialysis CKD patients?
4. Where an AI-native EMR fits — feature by feature
For dialysis units, 2026 is the year that proving you have the capacity in place decides 20 points per session. Here is how Pottech's AI-native EMR helps, feature by feature.
Feature 1: Billing and claims management — count toward the volume requirement
The automatic billing engine checks bundling, mutual exclusions, and frequency limits.
The capacity add-on's volume requirements — 24 home PD guidance fees a year, two transplants in the prior year — are requirements you can simply count. But if you are not in a position to count them, you find out you are short right before the transitional deadline. Continuous visibility into billing volume supports the filing decision itself.
Feature 2: Management analytics dashboard — treat 20 points as a management metric
Visit volumes, revenue per patient, and monthly trends are aggregated and visualized automatically.
Dialysis has a legible patients × sessions structure, which means unit price changes flow straight through to results. With roughly 3 million yen a year riding on the add-on, requirement attainment — drills completed, PD cases managed, coordination agreements — deserves monthly tracking as a management metric. Making the countdown to the transitional deadlines visible keeps the response from slipping.
Feature 3: Charting and orders — standardize PD clinic records
AI generates SOAP notes from the consultation audio, and set orders enter tests and prescriptions in one action.
When launching a peritoneal dialysis programme, the guidance record is the evidence behind the management fee. In the launch phase, workflows are not yet settled and record granularity tends to vary. Templates that standardize the format have practical value in reliably accumulating toward the 24-per-year requirement.
Also review what applies to every specialty
Consultation fees, the inflation add-on, the wage increase evaluation fee, and the electronic clinical information coordination add-on are collected in "what applies to every specialty."
Sources (principal)
- MHLW, "About the FY2026 Fee Schedule Revision" https://www.mhlw.go.jp/stf/newpage_67729.html
- Daitoku Oka, "Hemodialysis revaluation and the renal replacement capacity add-on" https://www.daitoku0110.news/p/artificial-kidney-revision-2026
- dialysis-dad-life, "2026 dialysis fee revision: point comparison" https://dialysis-dad-life.blog/medical-fee-revision-2026-dialysis/
- med-cpa, "Revisions to community comprehensive care add-ons" https://med-cpa.jp/hoshu-14/