Part 1: Proposed Clinical Measures for ESRD QIP PY 2015

On Thursday, July 19, the Centers for Medicare & Medicaid Services (CMS), Office of Clinical Standards and Quality (OCSQ), hosted an open door forum on end-stage renal disease (ESRD) Quality Incentive Program (QIP). The forum focused on proposed rule for operationalizing the ESRD QIP in payment year (PY) 2015.

The public has 60-days to submit any comments about the proposed rule.  All dialysis facilities and ESRD stakeholders are encouraged to review the proposed rule carefully and comment. The comment period will end on August 31. Based on the comments, a final rule will be published in November.

The Proposed Clinical Measures for PY 2015 have been expanded and an additional four new measure topics are included in the now total of seven clinical measures and these are:

• With Anemia Management, note that the hemoglobin measures have stayed the same from PY 2014.
• Kt/V Dialysis Adequacy measure topic is new and has been replaced by the Urea Reduction Ratio (URR).  Kt/V was originally proposed in PY 2014, but was not included in final rule. Each of the Kt/V Dialysis Adequacy addresses different population.
• Adult Hemodialysis (in-and-out  center)
• Percent of hemodialysis patient-months with spKt/V greater than or equal to 1.2
• Adult Peritoneal Dialysis
• Percent of peritoneal patient-months with Kt/V greater than or equal to 1.7 (dialytic +residual) during 4-month study period.
• Pediatric Hemodialysis
• Percent of pediatric in-center hemodialysis patient-month with spKt/V greater than or equal to 1.2
• Vascular Access Type (VAT) measure topic  have stayed the same from PY 2014
• Access via arteriovenous fistula (AVF)
• Access via catheter for 90+ days
• Hypercalcemia has new definitions and exclusions that was not seen in PY 2014. The clinical measure expands a reporting measure established the year before. It applies to every patient that is treated by a facility, not just to those on Medicare. 

A low-volume facility adjustment has also been added to the proposal for PY 2015. CMS wants to include as many facilities as possible in the ESRD QIP. In the past there was a minimum standard of 11 cases that were able to score a facility on a quality measure. For this year there is a new methodology proposed that will increase cases according to the previous methodology up to 25. This will allow CMS to have a more reliable measure score because of the increase in cases.  The facilities that have between 11 and 25 eligible cases will not be excluded. CMS has defined a calculation that can be applied to the measure rates of the facilities that gives the facilities "the benefit of the doubt" and increases the measure rates for the measures that have between 11 and 25 cases. A variation that might have caused your facility to have a lower measure rate, if you had many more patients, would be eliminated. No penalization will occur to any facility with this proposal.

For more information on scoring, additional proposals  and examples, log onto the CMS website and see the slideshow.