Rockwell Medical (RMTI) received FDA approval for Dialysate Triferic, a one-of-a-kind iron maintenance medication in January 2015. In clinical trials, Triferic demonstrated improved efficacy and less risk than currently approved intravenous iron products. Despite these advantages, the Centers for Medicare & Medicaid Services, CMS, issued a J-code that reimbursed dialysis centers for administration of Triferic within an existing fixed-priced bundle. Without an add-on reimbursement under the CMS Transitional Drug Add-On Pricing Adjustment, TDAPA, Dialysate Triferic represented an added cost to dialysis centers without adjustments to intravenous iron and Erythropoiesis Stimulating Agents, ESAs, for