RENAL COMMUNITY FIGHTS BUNDLE TRANSITION ADJUSTER

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RENAL COMMUNITY FIGHTS BUNDLE TRANSITION ADJUSTER
10 hours agoby Keith Chartier , Editor


WASHINGTON—With the new dialysis bundled payment looming, the renal community is asking the Centers for Medicare & Medicaid Services (CMS) to rethink a 3.1 percent cut in reimbursement designed to offset the potential increased costs of transitioning to the new payment system in 2011.

The National Renal Administrators Association (NRAA) as well as eight U.S. senators sent letters on Oct. 21 to CMS Administrator Donald Berwick, MD, voicing concerns that the 3.1 percent “transition adjuster” will hurt dialysis clinics.

They feel CMS underestimated the number of dialysis clinics that will fully opt in to the new payment system on Nov. 1. Therefore, the letters call on CMS to lower the transition adjuster in order to reflect more accurate projections.

“Dialysis providers are facing a difficult future with the dramatic changes in reimbursement, new requirements under the law and regulations and the uncertainty of being adequately compensated for their services,” NRAA President Diane Wish wrote to Berwick. “For the smaller dialysis organizations, whose Medicare margins are on the average are barely above break-even, any unnecessary reduction in reimbursement could have disastrous consequences. Certainly, a reduction of 3.1 percent when the data justifies a reduction of less than 1 percent is unfair and could very well mean the difference between a facility continuing to provide quality services to its dialysis patients or closing its doors.”

The new dialysis payment system, also known as the Prospective Payment System (PPS), is a single bundled case-mix adjusted payment to dialysis facilities for renal dialysis services, such as dialysis treatments and supplies, certain ESRD-related drugs, and ESRD-related clinical laboratory tests

In creating the new payment system, CMS was congressionally mandated to ensure that the 2011 bundle payment was 98 percent of the estimated total amount that would have been paid in 2011 under the old system of reimbursement.

“… we estimate that during the first year of the transition, total payments to all ESRD facilities would exceed the estimated payments under the ESRD PPS in the absence of the transition,” CMS wrote in July.

Therefore, the final payment rate includes a 1 percent reduction to account for outlier payments, a 2 percent reduction to achieve budget neutrality and the 3.1 percent transition adjustment for the first year of phase-in.

On Nov. 1, dialysis clinics must choose whether to be paid the full bundled rate or opt in to a four-year transition that will blend current payments with the new payments.

To determine the transition adjuster, CMS estimated that 43 percent of dialysis facilities will opt in to the full bundled payment and that 57 percent of ESRD facilities will choose to be paid the blended rate during the transition.

Many in the renal community, however, contend that these numbers are not accurate. "The preliminary estimate provided by CMS was not based on current data,” said DaVita spokesman Vince Hancock. “Once the Nov. 1 data is aggregated, we believe CMS should revise their estimate and implement the new transition adjuster by Jan. 1, 2011."

To gain a better understanding of the possible discrepancy, the NRAA surveyed its membership and found that 353 of 357 dialysis clinics—or 94 percent—said they would opt in to the new payment system in 2011.

“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,” Wish wrote to CMS. “If these numbers hold true, using CMS’ methodology, the transition adjustment should be minus 0.7 percent, not 3.1 percent.”

In addition to the NRAA letter, Sens. John Cornyn (R-Texas), Kent Conrad (D-N.D) , Scott Brown (R-Mass.), John Kerry (D-Mass.), Bill Nelson (D-Fla.), Pat Roberts (R-Kans.), Olympia Snowe (R-Maine), and Debbie Stabenow (D-Mich.) also wrote CMS expressing their concerns.

“Given the importance of the success of the PPS to patients, providers and the Medicare program, we urge CMS to revise the transition adjustment as soon as practicable to account for the submitted data,” the senators wrote. “Without a timely revision to reflect actual facility choices, the 3.1 percent planned transition adjustment will remain inaccurate and could lead to access problems for patients.”

http://www.renalbusiness.com/news/2010/10/renal-community-fights-bundle-transition-adjuster.aspx