Kidney Care Partners—a coalition of patient advocates, dialysis providers and manufacturers focused on improving the quality of care for individuals with chronic kidney disease—has released a 124-page public comment outlining concerns (7MB file) about a proposed rule from the CMS for renal-care providers.
Kidney group wary of proposed CMS rule
Announced on Sept. 15, the rule proposed a single, bundled payment to dialysis facilities that would cover items and services used in providing outpatient services, including dialysis treatment, prescription drugs and laboratory tests.
In its extensive comment letter to acting CMS Administrator Charlene Frizzera, Kidney Care Partners addressed the rule point by point, beginning with concerns about the rule's proposal regarding oral drugs for patients. “KCP questions CMS' legal authority to include oral drugs without an injectable equivalent in the payment bundle and is concerned that its proposal imposes burdens on patients and providers,” the letter said. “If CMS determines to move forward with its proposal, the agency must develop adequate data to ensure appropriate reimbursement and track patient outcomes following implementation, and the CMS should delay implementation of policy until such issues are addressed,” it continued.
The letter also highlighted concerns about home dialysis, saying the CMS should either maintain home dialysis training services outside the bundle or create a separate payment that recognizes the incremental costs of training services. It also requested that the CMS to explain in more detail its rationale for selecting 2007 as the year for basing the marketbasket. “We think the marketbasket base year should be after 2008 as it will more accurately represent the changes in facility operating costs due to the new conditions of coverage implemented during 2008 and 2009,” the letter said.
Initially scheduled to end on Nov. 16, the comment period for the end-stage renal disease proposed rule was extended for another 30 days.
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