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 statement from Pete Nevin, president of Koffel Medical Supply Inc.
My name is Pete Nevin, and I am here from Koffel Medical Supply Inc., a 23-year-old home dialysis supply company, which services and supports home dialysis patients and dialysis facilities throughout the country. Our market focus is in supporting and servicing patients from pediatric and small- to medium-sized dialysis programs. Our concerns are [that] the proposed rule calls for the elimination of Method II by removing a supplier’s ability to bill CMS directly. The rule is not providing a facility the ability to get adequately reimbursed for the training of home modalities; instead choosing to place it under the bundle, which could require months to recoup the cost of training—if at all. Also, it is not providing any additional reimbursement for the utilization of more frequent home modalities. This seems to contradict the CMS goal to drive the increased utilization of the more cost effective home modalities. It is widely documented that home modalities are less expensive than in-center treatments, and driving the utilization of those modalities can save the system money. With the ESRD population projected to exceed 700,000 patients by 2015, the costs implications of not increasing utilization of home dialysis will be staggering. Why then are you choosing to remove a very tool providers’ utilize in the establishment and expansion of home programs? As an ESRD supplier able to bill CMS directly under Method II, we remove the supply and equipment costs of home modalities from the facilities we support. This provides the facilities the economic flexibility needed to establish and grow home programs. Changing the current Method II format, to one where the facility would incur the costs of home supplies and equipment, places the financial burden squarely of the shoulders of these already financially strained pediatric and small-sized programs.
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