Kidney Community Submits to CMS Comments on ESRD Proposed Payment System, Quality Incentive Program and ESRD Treatment Choices Model
Summary
Washington, DC, August 08, 2022 --( PR.com )-- Kidney Care Partners (KCP) – the nation’s largest non-profit, non-partisan coalition of more than 30 organizations representing patients, professional care providers, and a wide range 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 address recommendations KCP has made related to both the End-Stage Renal Disease (ESRD) Prospective Payment System (PPS) and the End-Stage Renal Disease Quality Incentive Program (QIP)“We appreciate this opportunity to work with the Administration to improve access to high-quality kidney care and address health inequities too often seen in this population,” said John P. Butler, chair of KCP. “Our comments address policies that will greatly impact access to innovations and the quality of care for the approximately 37 million Americans living with kidney disease.”In its comments, KCP asks CMS to implement policy changes to help address the workforce crisis – which has a direct impact on the quality of care - that is threatening access to dialysis facilities and ensure that current policies do not make it more difficult for dialysis patients to obtain 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 impact on the ability to report quality data and the problems created by the pandemic.Moreover, KCP applauds CMS for including a Request for Information (RFI) that recognizes the problems with the current “no new money” policy related to adding a new product to the bundle. Given the chronic underfunding of this program, protecting patient access to innovative treatment options means that CMS should assess the payment rate and add new dollars even if the product being added to the bundle comes within what CMS has designated as an “existing functional category.” KCP also asks CMS to review the RFI comments and propose a policy for CY 2024 that will adjust the payment rate to support the long-term sustainable adoption of innovative products.The comments also call on CMS to ensure incentives to adopt innovation apply to patients enrolled in Medicare Advantage plans, targeting case-mix and facility-level adjustors, outlier policies, addressing concerns about oral-only drugs potentially coming into the bundle in 2025, and similar policies to prevent millions of dollars from being trapped within the federal government and not spent on patient care. While KCP recognizes and appreciates the efforts CMS has made to address some of the ongoing concerns the kidney care community shares with regard to the use of certain measures, the group also highlighted recommendations that have not been resolved. We hope the end policy result will provide for continued and sustainable, high-quality care for every American living with kidney disease and kidney failure,” Butler concluded.To view KCP’s QIP comment letter, click here To view KCP’s PPS comment letter, click here
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