Dialysis providers have 3 days left to decide new ESRD bundled payment formula

Dialysis providers have 3 days left to decide on new ESRD bundled payment formula
10/27/2010

Dialysis providers need to make a decision this week about whether they will opt in to the End-Stage Renal Disease Programs new bundled payment system, or agree to a "blended" payment rate for the next four years.

As part of the regulations of the new ESRD bundled payment system, which takes effect Jan. 1, providers can either opt in fully to the new reimbursement formula, which bundles all dialysis services, IV dialysis drugs, and lab tests related to dialysis care, under one payment, or accept a transitional rate that blends the clinics payment (25% bundled rate/75% current payment rate) for the first year and gradually increases the blend for the next four years. By 2014, all clinics will be paid under the ESRD bundled payment system.

If a provider does not notify CMS by Nov. 1 of their decision to opt-in to the ESRD payment bundle, CMS will automatically place them into the blended rate.

According to the Centers for Medicare & Medicaid Services, all dialysis providers should have been contacted by their Medicare administrative contractors/fiscal intermediaries with instructions on how to let CMS know about their payment choice. Yesterday, the National Renal Administrators Association sent out a list of intermediaries around the country. That list is available here.

Websites of Medicare administrative contractors/fiscal intermediaries

 NOTE: For some of the links, the user needs to accept the license disclaimer message before it will open the page.  

Jurisdiction 1 and 11 Palmetto 
 
Jurisdiction 2 and 14 NHIC 
 
Jurisdiction 3 and 6 Noridian

Jurisdiction 4 Trailblazer 

Jurisdiction 5 WPS  

Jurisdiction 7 Pinnacle Business Solutions 
 
Jurisdiction 9 First Coast Service Options 
Election in
Low Volume

 
Jurisdiction 10 CAHABA (unavailable)
 
Jurisdiction 12 and 15 Highmark

Election in
Low Volume

NRAA questioning CMS estimate on facilities opting in

Dialysis providers have been concerned about the impact of a 3.1% payment adjustment that CMS is making on the bundled payment. The transition rate is based on the election of clinics to opt into the new payment system. CMS is estimating that only 43% of dialysis clinics will choose to opt in 100% by Nov. 1 for the new bundled payment system; the rest of the providers will choose the blended rate. To make up for that ongoing, higher cost to the program, CMS is levying the transition rate on all providers.

In her weekly letter to members, NRAA president Diane Wish outlined results of a survey among members, most of whom manage small- to medium-sized dialysis organizations. In that survey, 353 of 375 facilities, or 94%, of those that responded, indicated that they would opt-in 100% to the new PPS system in 2011, while 22 facilities indicated they intend to participate in the four-year transition. While this is a small sampling, it does indicate that the CMS projection dramatically underestimates the number of facilities that intend to fully participate in the new prospective payment system, said Wish. If these numbers hold true, using CMS methodology, the transition adjustment should be minus 0.7 percent, not 3.1%.

The Kidney Care Council, which represents for-profit dialysis providers, is also conducting a survey among its members about opting into the bundle, Executive Director Cherilyn Cepriano told NN&I. Those results are expected soon. Cepriano said KCC members represent 85% of dialysis patients in the United States.
 
Wish sent a letter on Oct. 13 to CMS administrator Donald Berwick on behalf of the NRAA, urging him to re-examine the proposed transition adjuster, base the reduction on actual data, and apply the new calculation to the 2011 reimbursement rate rather than waiting to make a change in 2012 as proposed in the PPS final rule.

 A letter was also sent to Berwick from several U.S. Senators asking the agency to revise the transition adjustor as soon as practical based upon the actual number of facilities that opt-in.

 CMS is not sure that they have the authority to make an adjustment without going through the rulemaking process, Wish said. While the industry is working with CMS, we are also working on a legislative fix as well.

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