CMS published in the July 5 Federal Register a proposed rule that would update and make revisions to the ESRD Prospective Payment System (PPS) for calendar year 2018, and set forth requirements for the ESRD Quality Incentive Program (QIP) for payment years 2019 through 2021. Comments are due August 28. AKF will be submitting a response and will focus our comments and recommendations on ensuring patient access to dialysis treatment and high quality care.

A summary of the proposed updates to the PPS and QIP can be found in this fact sheet from CMS. In addition to those proposed changes, CMS is seeking stakeholder feedback on the following broader topics as CMS considers potential future changes to the Medicare ESRD program:

  • Accounting for social risk factors such as in the ESRD QIP. CMS understands that social risk factors such as income, education, employment, race and ethnicity, social support, and community resources play a significant role in health. CMS is seeking public comment on whether they should account for these factors in the ESRD QIP, and if so, what methods would be most appropriate for accounting for these social risk factors. Examples of methods include: adjustment of the payment adjustment methodology under the ESRD QIP; adjustment of provider performance scores; confidential reporting of stratified measure rates to facilities; public reporting of stratified measure rates; risk adjustment of a particular measure as appropriate based on data and evidence; and redesigning payment incentives (for instance, rewarding improvement for facilities caring for patients with social risk factors or incentivizing facilities to achieve health equity).
  • Solicitation of comments on the inclusion of Acute Kidney Injury (AKI) patients in the ESRD QIP. Currently, facilities are not required to report AKI patient data for any ESRD measure, but CMS intends to require facilities to do so in the future. CMS is seeking public comment on whether and how to adapt any of the current measures to include the AKI population, as well as the type of measures that might be appropriate to develop for future inclusion in the QIP that would address the unique needs of beneficiaries with AKI.
  • Request for Information on Medicare Flexibilities and Efficiencies. CMS is seeking ideas for regulatory, sub regulatory, policy, practice, and procedural changes to the Medicare program to better accomplish the goals of improving quality, lowering costs, improving program integrity, and making the health care system more effective, simple and accessible. Ideas could include payment system redesign; elimination or streamlining of reporting, monitoring, and documentation requirements; aligning requirements across programs; and enhancing operational flexibility and facilitation of individual preferences.