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Kidney Community Submits to CMS Comments on ESRD Proposed Payment System, Quality Incentive Program and ESRD Treatment Choices Model

Washington, DC, August 08, 2022 –(–Kidney Care Partners (KCP) the nations largest non-profit, non-partisan coalition greater than 30 organizations representing patients, professional care providers, and an array of kidney care stakeholders thanks the Centers for Medicare & Medicaid Services (CMS) for proposing new policies in the CY 2023 Changes to the End-Stage Renal Disease (ESRD) Prospective Payment System and Quality Incentive Program Proposed Rule that seek to handle recommendations KCP has made linked to both End-Stage Renal Disease (ESRD) Prospective Payment System (PPS) and the End-Stage Renal Disease Quality Incentive Program (QIP)

We appreciate this possibility to use the Administration to boost usage of high-quality kidney care and address health inequities all too often observed in this population, said John P. Butler, chair of KCP. Our comments address policies that may greatly impact usage of innovations and the grade of look after the approximately 37 million Americans coping with kidney disease.

In its comments, KCP asks CMS to implement policy changes to greatly help address the workforce crisis that includes a direct effect on the standard of care – that’s threatening usage of dialysis facilities and make sure that current policies usually do not make it more challenging for dialysis patients to acquire phosphate binders and phosphate lowering drugs.

In the context of the ESRD quality program, KCP requests that CMS suspend the penalties in the value-based purchasing program, given the ongoing effect on the opportunity to report quality data and the issues developed by the pandemic.

Moreover, KCP applauds CMS for including a Obtain Information (RFI) that recognizes the issues with the existing no new money policy linked to adding a fresh product to the bundle. Beneath the current policy, CMS wouldn’t normally adjust the payment rate when certain new, innovative products are put into the bundle. Given the chronic underfunding of the program, protecting patient usage of innovative treatment plans implies that CMS should measure the payment rate and add new dollars even though the merchandise being put into the bundle comes within what CMS has designated being an existing functional category. KCP also asks CMS to examine the RFI comments and propose an insurance plan for CY 2024 that may adjust the payment rate to aid the long-term sustainable adoption of innovative products.

The comments also ask CMS to make sure incentives to look at innovation connect with patients signed up for Medicare Advantage plans, targeting case-mix and facility-level adjustors, outlier policies, addressing concerns about oral-only drugs potentially getting into the bundle in 2025, and similar policies to avoid huge amount of money from being trapped within the government and not allocated to patient care. KCP also supports providing flexibilities that support care coordination the type of who provide services to individuals coping with kidney disease and kidney failure.

On quality, KCP notes that the ESRD QIP value-based purchasing program provides important quality performance information that promotes patient-driven decision-making. However, the pandemic has disrupted data reporting and skewed measure outcomes, rendering it inappropriate to use penalties to facilities still battling the pandemic. KCP asks CMS to suspend the penalties for these facilities, in the same way it did for hospitals along with other Medicare providers with value-based purchasing programs. Considering that individuals coping with kidney disease are particularly at-risk for COVID-19 infection, re-infection, and experiencing complications from the condition, the kidney care community asks CMS to take into account the general public health emergencys effect on the dialysis population and on reporting.

Finally, KCP notes its support for streamlining the QIP and making certain performance evaluation measures are meaningful to individuals who require dialysis and reflect the specific performance of dialysis facilities. While KCP recognizes and appreciates the efforts CMS has designed to address a few of the ongoing concerns the kidney care community shares pertaining to the usage of certain measures, the group also highlighted recommendations which have not been resolved. This consists of the release of specific measures, universal rate measures, addressing health inequities, and promoting transparency.

As a residential area, we anticipate continued use CMS and applaud its recognition that there surely is a real have to increase funding for innovative kidney care. Hopefully the finish policy result provides for continued and sustainable, high-quality look after every American coping with kidney disease and kidney failure, Butler concluded.

To see KCPs QIP comment letter, just click here.

To see KCPs PPS comment letter, just click here.

Kidney Care Partners

Sarah Feagan




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