We are all aware, that, on Sept. 15, 2009, the Centers for Medicare & Medicaid Services issued the proposed rule for perhaps the most significant change in renal dialysis reimbursement since the introduction of the composite rate in 1983.
Since November, much has been said and many responses have been sent to CMS with respect to suggestions for improving the proposed bundle. It is possible that by the time you read this article the final rules will already have been issued, the rule will be cast-in-stone so to speak and the next item confronting dialysis facilities will be dealing with the financial and operational challenges of how CMS implements the new payment system on Jan. 1, 2011.
The following are some general suggestions that will assist all concerned in managing the shift to a new payment bundle.
1. Avoid budgeting 2011 income solely based on intuitive or theoretical assumptions regarding how the bundle will impact your bottom line.
2. Avoid groupthink. Remember, with the prior change to case-mix index many providers found that the financial impact was not the impact predicted or expected based on comments at the various renal meetings and symposiums.
3. Budget for 2011 using detailed information based on a representative sample of your patients, such as an average month’s census using a numerical model. The model should not only be accurate with respect to its developer, e.g., CMS, but should ideally be understood and discussed by several people at your facility. I have seen where objectively great payment prediction applications have yielded inaccurate results simply because of a minor misunderstanding or mistake with the data input by the user.
4. If there is a shift in incentive with respect to resource utilization, attempt to clearly define and carefully consider what this means to you and to your patients.
These are only a few general suggestions. The key is to be forward looking and proactive, don’t wait for the end of the first quarter of 2011 to discover how the new bundle has impacted you.
Now for some seasonal reflections. Last year has been a year of momentous change. We have a new president, apparently have weathered the financial crisis and are entering a new era in renal reimbursement. But we should not let these momentous items allow us to forget why we work so hard to provide quality care, both for our patients, our friends, and families.
