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FOR IMMEDIATE RELEASE
Media Contact:
Tenee Hawkins
Director of Communications
404.658.1423
thawkins@kidneyfund.org
American Kidney Fund Testifies at CMS Town Hall Meeting
BALTIMORE (Oct. 23)—The American Kidney Fund (AKF) today submitted testimony at a Centers for Medicare and Medicaid Services town hall meeting on the End Stage Renal Disease Prospective Payment System Proposed Rule. LaVarne A. Burton, President and Chief Executive Officer of the American Kidney Fund, addressed the American Kidney Fund’s concern with three areas: drug bundling, cost sharing and disparities.
Following is the full text of the American Kidney Fund’s testimony:
Good Morning. My name is LaVarne Burton, and I am President and Chief Executive Officer of the American Kidney Fund. Thank you for convening this town hall meeting. I am here to represent the voices of a vulnerable patient population—individuals with chronic kidney disease and kidney failure.
Our mission at the American Kidney Fund is to fight kidney disease through direct financial support to patients in need; health education; and prevention efforts. We provide treatment-related financial assistance to nearly 1 out of every 5 dialysis patients in the U.S. We help low-income patients maintain their health insurance coverage, and we help them to pay out of pocket costs for medications covered under Part D, as well as other treatment-related expenses not covered by their insurance.
We applaud CMS for its commitment to promoting efficiency in the quality of care for individuals living with ESRD.
We appreciate the opportunity to address three issues of particular concern to ESRD patients: drug bundling, cost sharing, and disparities.
Bundling of Drugs and Patient Cost Sharing
With regard to drug bundling, the American Kidney Fund has several serious concerns.
First, we are concerned that bundling will limit patient access to the most clinically appropriate drugs. Dialysis patients take numerous oral medications that do not have intravenous equivalents. Each patient has a different health condition and could require a blend of multiple drugs. In addition, there are not adequate clinical metrics to monitor impacts of changes in drug regimen on patients. How do we ensure that patients will be administered the most clinically appropriate drug, versus simply the least costly?
Second, the administrative mechanisms for having patients receive their renal medications through one source and non-renal medications through a different source mean that we will not provide overall monitoring to protect patients against possible adverse drug interactions.
Third, we are concerned that bundling will limit manufacturers’ incentives to develop new, innovative drugs to combat renal disease. If limiting costs becomes a primary driver of prescription decision-making, there will be little incentive for research and development of new drugs. Are we expecting health outcomes for kidney patients to remain static?
Fourth, we are concerned that including Part D drugs in the bundle would eliminate patient access to support that assist with co-pays, such as the Medicare Low Income Assistance program as well as programs such as the American Kidney Fund’s Part D Bone Medication. Access to such assistance is vital. Let me share with you one example. A retired industrial firefighter in Louisville, Kentucky, recently wrote to us to let us know that he had been prescribed medication for treatment of secondary hyperparathyroidism at an out-of-pocket cost of $600 a month. “I couldn’t afford it,” he said. “I did what I could but occasionally I had to take half doses or share with friends on the same prescription.” Because he was not taking clinically appropriate doses of his medication, he was scheduled for a parathyroidectomy to treat his condition. But fortunately, he was able to enroll in the American Kidney Fund’s program that helps with costs under Part D—and as a result, he avoided surgery. He is now taking his medication, as prescribed, because our assistance program helps him to afford it.
In short, we believe that including in the payment bundle Part D oral drugs that do not have intravenous equivalents will have an adverse impact on patients and we remain opposed to this provision until issues of quality and access have been addressed.
Patient Cost Sharing and Co-Insurance
We also have major concerns regarding patient 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. When drug, laboratory, and other costs are added to the bundle, the out of pocket costs that patients must pay will be far greater than their current monthly co-pays and expenditures. For lab services, Medicare patients currently have no co-insurance obligations—and dialysis patients incur many lab costs on a routine basis. The proposal will significantly increase patient out of pocket payments. This is very troubling for a patient population that is already economically vulnerable and often unemployed because of the time demands of receiving dialysis treatment.
Case Mix Adjustors
Finally, we are concerned about the lack of adequate case-mix adjustors for race. African Americans, Latinos, Native Americans and Asian Americans suffer disproportionately from ESRD. African Americans represent 12 percent of the U.S. population, but are 30 percent of those on dialysis. Despite the fact that CMS has historically acknowledged that African American patients require higher doses of ESA’s in order to control anemia, CMS does not account for race as a case mix adjustor for the payment structure. CMS has repeatedly committed to developing such an adjuster and should move immediately to do so.
While we recognize that there are challenges in the data used to evaluate race as an adjustor, The American Kidney Fund 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. 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.
Conclusion
We trust that CMS will consider our positions and views as it relates to the Proposed Rule on the ESRD Payment System. Thank you for the opportunity to voice the concerns of the American Kidney Fund and the many patients we serve.
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About the American Kidney Fund
The mission of the American Kidney Fund is to fight kidney disease through direct, treatment-related financial support to patients in need; health education; and prevention outreach. In 2008, the American Kidney Fund provided treatment-related grants to 75,000 kidney patients totaling more than $119.5 million. The American Kidney Fund reaches tens of thousands of individuals each year with information about kidney health; operates a kidney disease screening program in high-risk communities; and maintains a toll-free HelpLine (866-300-2900) which provides education about kidney disease. The American Kidney Fund is a seven-time recipient of the highest “Four Star” rating from Charity Navigator; holds an A+ rating from the American Institute of Philanthropy; adheres to the National Health Council Standards of Excellence; and is a member of the Better Business Bureau Wise Giving Alliance. For more information, visit www.kidneyfund.org.
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