Let CMS Know that Proposed Rule on ESRD Payment System Will Hurt Patients!

The Centers for Medicare and Medicaid Services (CMS) recently released its proposed rule on changes to the ESRD Payment System which will require Medicare to combine (or “bundle”) dialysis patient services and drugs into one payment. The American Kidney Fund is concerned about how this rule will impact dialysis patients.

• Drug Bundling - We believe that including in the payment bundle Part D oral drugs that do not have intravenous (IV) equivalents will have an adverse impact on patients and we remain opposed to this provision until issues of quality and access have been addressed.
   
• Cost Sharing- The proposed payment structure will be burdensome for patients.  The proposed rule imposes a patient co-insurance of 20 percent on the entire bundled ESRD payment.  This means, for example, that dialysis patients will have to pay 20% of the cost of lab services while other Medicare patients do not have to make such a payment.
    
• Disparities - AKF recommends that CMS refine its data sources and commit to a definite timeframe for completing this work so that a race/ethnicity adjustor may be factored into the reimbursement policy.  Research has shown and CMS acknowledges that race is a significant predictor of the cost of care.  In the meantime, CMS should not go forward with the proposed rule without some placeholder mechanism to recognize the impact of race on the cost of dialysis. 

The American Kidney Fund will submit an official comment letter to CMS and encourages everyone to review the rule and also share their comments with CMS.  View a copy of the proposed rule and submit comments at www.regulations.gov Document ID: CMS-2009-0083-0006.