The following is a statement from the National Kidney Foundation in response to an interim final rule issued by the Centers for Medicare and Medicaid Services, regarding dialysis companies providing premium assistance for individual marketplace plans either directly, or through a third party. 

The National Kidney Foundation is pleased that the Centers for Medicare & Medicaid Services (CMS) has given serious consideration to how best protect dialysis patients from being steered into health insurance options that primarily benefit the provider; but may not necessarily meet health care and financial needs. Ensuring end stage renal disease (ESRD) patients are making informed decisions about their insurance coverage is a very important goal.

However, we have concerns about the requirement which states facilities must obtain written consent from insurers that they will accept third party premium assistance. This appears to allow insurers to reject third party premium assistance for ESRD patients, even when that assistance is provided by charitable non-profit organizations. It would also give insurers a greater opportunity to discriminate against third party-premium assistance intended to help support ESRD patients in obtaining their choice of coverage.

The CMS ruling also requires additional responsibility for dialysis facilities to deliver comprehensive education to patients on insurance options in the marketplace as well as public coverage options.  Patients often turn to social workers for questions about insurance; however, social workers are not trained to provide insurance counseling.  If this added responsibility falls to social workers, it may further detract from the work they are trained and licensed to do—improving the health of kidney patients and connecting them to any external support services these patients may need.

The National Kidney Foundation does not provide premium assistance to help kidney patients pay for health insurance coverage nor do we counsel patients on the type of coverage they should choose.  We do provide factual information and tools to help patients learn about their options and make informed decisions that best serve their unique needs.  For more information visit