A proposed rule released by the Centers for Medicare & Medicaid Services July 2 projects that the updates in the End-Stage Renal Disease Program’s payment bundle for 2015 would increase payments to dialysis facilities by 0.3% to 0.5%, while rural facilities will receive a decrease of 0.5%. CMS projects that ESRD facilities in Puerto Rico and the Virgin Islands will receive a 3.6% decrease in estimated payments, based on the proposed rule.
CMS also released details on proposed changes to the ESRD Quality Incentive Program for payment year 2017 and 2018. A new reporting measure for hospital re-admissions would be added next year, but the agency is proposing major expansion and reorganization of the QIP for payment year 2018.
The rule for both regulations will be published July 11 in the Federal Register, and the renal community will have until Sept. 2 to respond.
Paying off the cuts
The proposed payment increase in the bundle was small for 2015 because dialysis facilities will be making another down payment on a 12% cut implemented by CMS last year. Congressional action this year watered down the impact of the cut and tied it to the annual market basket update. As a result, CMS projects that the ESRD bundled market basket update would have been 1.6% for 2015. However, CMS is using the annual market basket updates to help cover payments for the 12% cut, which the agency agreed to spread out over several years. In addition, CMS would apply a proposed wage index budget-neutrality adjustment factor of 1.001306, resulting in a 2015 ESRD PPS base rate of $239.33.
Changing the marketbasket
Other pieces of the proposed rule to update the PPS include:
- CMS proposes for FY 2015 to rebase and revise the ESRD bundled market basket. Rebasing involves using the most recent year of available data, CY 2012, to reflect the input costs faced by ESRD providers under the bundled system compared to 2008 data used for the current market basket.
- Under the ESRD PPS, ESRD facilities may qualify for outlier payments for high cost patients. For CY 2015, CMS proposes to use CY 2013 claims data to update the outlier services’ fixed-dollar loss and Medicare Allowable Payment (MAP) amounts.In CY 2015, CMS is not proposing any changes to the application of the wage index and will continue to apply the adjustment to the labor-related share portion of the base rate when making payments under the ESRD PPS.
- CMS is clarifying the eligibility criteria for the Low Volume Payment Adjustment and proposing to amend the supporting regulations in the Code of Federal Regulations.
CMS releases details on the next era of the QIP
A new reporting measure that will capture hospital readmissions data and removal of hemoglobin as a measurable indicator are part of the proposed changes to the Quality Incentive Program for next year. There will be eight clinical measures and three reporting measures, encompassing anemia management, dialysis adequacy, vascular access type, and patient experience of care, infections, hospital readmissions, and mineral metabolism management. Five of the proposed PY 2017 clinical measures would be captured in two clinical measure “topics” or categories (Kt/V Dialysis Adequacy and Vascular Access Type). Aside from the newly proposed Standardized Readmission Ratio (SRR) measure, CMS is proposing to revise the National Healthcare Safety Network (NHSN) Bloodstream Infection in Hemodialysis Outpatients measure to calculate facility performance using the Adjusted Ranking Metric. CMS is not proposing to make any changes to the Hypercalcemia measure or to the measures in the Kt/V Dialysis Adequacy measure topic or Vascular Access Type measure topic. The rule also proposes to remove the Hemoglobin Greater than 12 clinical measure because it is “topped out,” CMS said.
The three proposed reporting measures include the In-Center Hemodialysis Consumer Assessment of Healthcare Providers and Systems (ICH CAHPS), Anemia Management, and Mineral Metabolism. CMS is not proposing to make any changes to the specifications for the Anemia Management and Mineral Metabolism reporting measures, and it is not proposing any changes to the way the three reporting measures are scored. However, the agency is proposing that facilities will no longer have the option to attest that they only had one qualifying case to avoid being scored on the reporting measures.
Proposed changes for PY 2018
The agency is anticipating more significant changes in payment year 2018, proposing the QIP measure set (applicable for performance year 2016) will contain eleven clinical measures and five reporting measures encompassing anemia management, dialysis adequacy, vascular access type, patient experience of care, infections, mineral metabolism management, safety, pain management, depression management, and hospital readmissions.
In an effort to align the ESRD QIP with other Value-Based Purchasing (VBP) and quality reporting initiatives, CMS said it is proposing to re-organize the clinical measures into a Clinical Measure-Domain with component subdomains tracking to the CMS Quality Strategy.
- The proposed Safety subdomain, accounting for 20% of the Clinical Measure Domain score, would include the NHSN Bloodstream Infection in Hemodialysis Outpatients measure.
- The proposed Patient and Family Engagement/Care Coordination subdomain, accounting for 30% of the Clinical Measure Domain score, would include the ICH CAHPS measure and the Standard Readmission Ratio measure.
- The proposed Clinical Care subdomain, accounting for 50% of the Clinical Measure Domain score, would include the Standard Transfusion Ratio (STrR) measure, the Kt/V Dialysis Adequacy measure topic, the Vascular Access Type measure topic, and the Hypercalcemia measure.
New clinical measures proposed for PY 2018 include ICH CAHPS (converted from a previous reporting measure), STrR, and Pediatric Peritoneal Dialysis (part of the Kt/V Dialysis Adequacy measure topic).
The rule for PY 2018 proposes to adopt five reporting measures. CMS is proposing to continue using the Anemia Management reporting measure, but is proposing to revise the Mineral Metabolism measure to allow facilities to submit serum and plasma phosphorus data. CMS is also proposing to adopt three new reporting measures: Pain Assessment and Follow-Up, Clinical Depression Screening and Follow-Up, and NHSN Healthcare Personnel Influenza Vaccination.