In a letter sent April 15 to acting CMS administrator Marilyn Tavenner, representatives of four dialysis patient organizations urged the agency, saddled with a request from Congress to find $5 billion in savings in the ESRD Program, to be careful not to “destabilize” the ESRD bundled payment system for dialysis providers and “jeopardize access to life-saving dialysis treatments” when considering payment cuts.
“Generally speaking, the implementation of the ESRD prospective payment system (PPS) and ESRD Quality Incentive Program (QIP) has been remarkably smooth. It is a positive example of how the Agency can work with interested parties to reform a Medicare payment program effectively,” wrote Lori Hartwell of the Renal Support Network, LaVarne A. Burton of the American Kidney Fund, Hrant Jamgochian, JD, LLM, of Dialysis Patient Citizens, and Dolph Chianchiano, a health policy advisor for the National Kidney Foundation. “CMS’s own data showing that patient outcomes have improved or remained high in most cases throughout this transition.
“We believe it is important that care be taken to ensure that the system is not harmed.”
CMS needs to propose a payment adjustment to the ESRD Program bundle to meet savings requirements imposed by the American Taxpayer Relief Act of 2012 (ATRA). The savings will help pay for health care reform efforts, including a $138 billion cost over 10 years to stabilize Medicare physician payments.
“While we appreciate that the secretary must implement the provision of the ATRA, such implementation should not undermine the stability of the current system, which would threaten access to this life-sustaining care for beneficiaries, ” the organizations wrote. “As your team considers how to comply with the new provision, they should take into account the other provisions of the ESRD statute. Specifically, CMS has an obligation to make sure that payment amounts are related to the cost of providing care or other economic and equitable factors. Thus, while it is clear that the Congress has instructed the Agency to implement a reduction in the payment amount to reflect changes in the utilization of certain drugs, it did not change this underlying statutory obligation. The final payment amount should still cover the actual cost of providing services to beneficiaries. “
The organizations said one possible fallout of cuts to the program might be clinics cutting staff and stretching patient-staff ratios, or cutting back on desirable dialysis options, like in-center nocturnal. “Medicare beneficiaries also are concerned that facilities could close, requiring longer drive times to receive care. For patients, this may mean less time to work or to care for their families, reducing how they view their quality of life,” they wrote.