FOCUS ON FINANCE: New Conditions for Coverage vs. Your Bottom Line

WE, WHO HAVE WORKED IN DIALYSIS FOR SEVERAL DECADES, have seen time and time again: The Only Constant is Change.

This past April 15 was not only “tax day” but also the Federal Register publication date for the long-awaited final version of the revised Conditions for Coverage for ESRD facilities (CfCs).

Not since 1976 has Medicare completely revised the CfCs, so some of you might be wondering what the revision of CfCs will do to change the day-to-day operations, as well as the cost of providing renal care.This article is the first of several looking at the CfCs through a financial lens, and as always, your comments are invited as we delve into the business implications of CMS’s CfCs.

What are Conditions for Coverage?

First a brief primer defining CfCs, and contextualizing where they fit in among the myriad of regulations and requirements faced by renal providers.

Most of us are familiar with the State Facility Survey and its accompanying on-site visit. The CfCs, as defined by CMS, are to a large extent the criteria used by state surveyors to certify a facility as qualifying for Medicare payment.

The simplest way of thinking about CfCs, also known as “health and safety requirements,” is that they define the sine qua non operational and organizational requirements for handling a Medicare patient. Failing to meet these requirements could be fatal to your unit, altogether preventing you from handling Medicare patients.

Since most commercial insurers and Medicaid participation agreements require meeting Medicare standards for certification, payment from all payers will be impacted by failing to meet the CfCs. So, in terms of the board game, Monopoly, one might say failing to meet CfCs means “don’t pass go, and definitely don’t collect $200.”