Back in July we shared the Centers for Medicare & Medicaid’s (CMS) proposed changes to dialysis payment and quality incentive program.  After gathering input from kidney patients and professionals we issued formal comments to CMS, which included recommendations for revising their proposals to strengthen patients’ access to high quality care.

Our concern about the proposed changes to payment is that rural facilities that already, on average, lose money treating Medicare patients would receive payment cuts.     Dialysis providers are likely to close facilities that continue to lose money, which could cause patients to face greater transportation challenges if they have to commute further for dialysis.  NKF recommended that CMS make changes to the way it pays for dialysis to ensure facilities in rural areas are able to cover the costs of providing the care that is needed to improve the health of their patients.

In addition to proposing changes to how CMS calculates payment for dialysis services, CMS proposed changes to the Quality Incentive Program (QIP), which requires dialysis facilities to report their performance on certain quality measures.  Facilities that don’t achieve a high enough score on the quality measures may receive a cut of up to 2% in their payment from Medicare.  You can see how your facility performed on the 2012 measures here.

(Tip: there is a tiny magnifying glass in the upper left corner of the data table – click on that and you can search for a facility by entering your zip code and then clicking on the number for the facility that you are interested in seeing scores.  The score will appear at the bottom of the table).

Since CMS implements the QIP penalty 2 years after the data is collected, changes to the QIP measures are published 2-3 years in advance so that dialysis facilities will know what measures they will be evaluated on and will have the opportunity to make improvements before the data is collected.  In this proposed rule, CMS wants to change the measures that will be used to assess penalties in 2017 and 2018.  CMS will collect the dialysis facility performance data for 2017 in 2015 and in 2016 for 2018.  In 2017 and 2018, CMS proposes to remove certain measures and add new ones in order to drive facilities to improve upon the health of their patients.

NKF supported CMS’s proposed changes to the future quality measures as we believe that they will drive greater improvements in patient care.  However, for a number of the measures we did suggest changes.  For example, we believe that dialysis facilities should be measured on hospital readmissions and blood transfusions that are within the power of the care team at the dialysis facility to prevent.  We also offered suggestions to strengthen the proposed measure requiring facilities to screen patients for depression.  NKF believes it’s not only vital that facilities assess patients for signs of depression, but that they also develop a care plan when a patient shows signs of depression so that patients can get the care they need, whether it’s through the dialysis facility’s social worker or through a referral for more specialized care.

NKF was also pleased that in 2018, CMS proposes to take responses from the In-center Hemodialysis Consumer Assessment of Healthcare Providers and Systems (ICH CAHPS) survey and measure facilities based on how patients feel about staff communication.  In a survey of dialysis patients, NKF found that 82% of patients stated that staff attentiveness was the most important factor in how they judged the quality of their care.  As CAHPS is an opportunity for dialysis patients to have a say in how well their facility is delivering their care, NKF of course supported including this measure in the QIP.

You can view NKFs full comments to CMS here.  The final rule from CMS is expected to be published in November.  We will be sure to let you know the results.