Editor’s Note: The Centers for Medicare & Medicaid Services held a town hall Oct. 23 to discuss the proposed bundled payment rule for the End-Stage Renal Disease Program. The following was the prepared statement from Connie Anderson, BSN, MBA, vice president of clinical operations for the Northwest Kidney Centers.
My name is Connie Anderson, and I am the vice president of clinical operations for the Northwest Kidney Centers in Seattle, Wash.
I want to thank CMS for having this town hall meeting and allowing us to provide comments regarding the proposed bundle.
I am here to represent the Northwest Kidney Centers, which is a not-for-profit, community-based, small dialysis organization that provides in-center, as well as home dialysis treatments. We currently serve about 1,365 patients. Of those patients, 63 are on home hemodialysis and 138 are on peritoneal dialysis. We are one of the largest single providers of home therapies.
NKC fully supports the efforts of CMS to revise the payment systems for the ESRD program. It is imperative that CMS should provide policies so that the ESRD beneficiaries receive the best quality of care and that care is not compromised in any manner. I would like to offer the following comments on behalf of NKC.
I wish to acknowledge CMS for many positive features in the bundle.
1. Payment is on a per treatment basis.
2. Nephrologists’ services are not included in the bundle.
3. Recognition of payment for more frequent hemodialysis with medical justification.
I would like to offer comment on two issues in the bundle that could have a negative impact on the care provided to our patients.
1. Laboratory Services
As an SDO [small dialysis organization], we contract for lab services with an outside vendor. Proposed in the bundle are all diagnostic laboratory services for the treatment of ESRD as ordered by the MCP physician. We felt this will impact the care provided to the ESRD patient for the following reasons. Annualized, NKC performs about 131,000 separable billable lab tests at a cost of about $32.57/treatment. All NKC labs are done through a contracted lab service, and many of the separable billable labs are for treatment of other disease states.