Editor’s Note: The following is a copy of comments submitted to the Centers for Medicare & Medicaid Services by the Home Hemodialysis Work Group in regards to the End-Stage Renal Disease Prospective Payment System, or the bundled payment. The work group represents physicians, patients, facilities, patient organizations, and renal professional organizations, all with an interest in preserving and enhancing patient access to home hemodialysis.
PPS Comments from the Home Hemodialysis Work Group
Ms. Charlene Frizella, Acting Administrator
Centers for Medicare & Medicaid Services
Department of Health & Human Services
Attention: CMS-1418-P
P.O. Box 8010, Baltimore, MD 21244-8010
Re: CMS-1418-P; ESRD Bundled PPS Proposed Rule
The Home Hemodialysis Work Group, a coalition made up of patients, patient organizations, providers, physicians, and renal organizations appreciates the opportunity to provide these comments regarding CMS 1418-P (The Proposed Rule). Our coalition was founded based on a shared interest in maintaining patient access to home dialysis therapies.
We applaud CMS’s articulated support for home dialysis within the proposed rule and concur with CMS on the importance of protecting and expanding beneficiary access to home dialysis options. Although utilization of all home modalities trail what most believe is ideally appropriate based on patient outcomes, quality-of-life, and total cost of care measures, we believe that current home hemodialysis access is particularly restricted. Only 15% of dialysis clinics offer home hemodialysis training services and only 1% of patients currently are treated with the modality. Payment policy change through the expanded bundle can clearly remove current barriers to access, and help the Agency and the kidney care community to achieve its stated goals.
Certain elements of the proposed rule clearly support home dialysis modalities. Specifically, a single bundled payment that is independent of location will facilitate all home home therapies and will remove some of the historical disincentives related to separately billable injectibles. Moreover, we believe the per treatment unit of payment and the retention of the current policy allowing providers to bill for all medically justified treatments delivered are essential elements of a supportive bundle.
