CMS is aware of the need for, and the potential impact of these HHD related changes. In last year’s rule-making process, a significant number of comments referenced the need for training payment modernization. CMS responded publicly that although that year’s rulemaking scope would not include a training payment change, it was something to be considered and addressed in future rulemaking.
Also in 2011, CMS contracted an analysis through the University of Michigan Kidney Epidemiology and Cost Center (UM-KECC) that showed that:
- On average CMS’ Fiscal Intermediaries and Medicare Administrative Contractors pay for medically-justified more frequent treatments (averaging 4.2-4.5 treatments per week) although payment practice varies widely by jurisdiction,
- That beneficiaries experience reduced access in those jurisdictions with lower or less certain payment.
Finally, MedPac in its March 2012 report highlighted the need to address certain issues, and suggested even that some portion of the IV/ESA savings might be directed toward payment of more frequent and HHD.
As of the writing of this article, CMS is again missing the opportunity to directly address these issues thus far in its rulemaking process for 2013. The proposed prospective payment system (PPS) rules make absolutely no mention of HHD. In the proposed physician payment rules, physician monthly capitated payments (MCP) for some in-center dialysis codes receive an increase, while the physician MCP for home dialysis remains unchanged.
Thus, the proposed rules would have the net impact of further reducing the incentives increasing the barriers toward physician and provider provision of HHD.
To go another year without addressing the issues would be a serious injustice to patients. This would only perpetuate the way that dialysis care is provided today, where over 90 percent of patients receive their care in-center and most are not even made aware of home and more frequent dialysis options.