NxStageUsers along with many other advocasy groups have come up with their own version of an action plan regarding the CMS Bundling that is quickly approaching. Please read the following to see how you can make a difference and an outline of what you should submit to CMS.
NxStageUsers Home Dialyzor Action Plan for BundlingCreate cheat sheet to lead people through the open comment period. Agree with what we like and ask more than what we can get.
All comments to CMS should be blind copied to us. We need to match responders to Congressional districts for follow up for bundle and afterwards for future action. It’s a good idea we do this regardless with NxStage dialyzor base. We should have database expanded for Congressional District field and have CS modify for each. All we need is zip+four. Intro to End Stage Renal Disease Prospective Payment System Last year, Congress passed the Medicare Improvements and Patients and Providers Act (MIPPA). This legislation requires the Centers for Medicare and Medicaid Services (CMS) to develop a new payment plan for the bundling of dialysis services. It is the most far reaching change in the way Medicare pays for dialysis since 1983. For the last 26 years, dialysis was paid for with what was call the “composite rate”. This included the dialysis treatment, certain injectable med and some labs. The new “bundling system is to be phased in over four years beginning in 2011. Bundling will include the dialysis treatment, all meds considered for renal failures, including epo and orals, and all labs. This represents a significant change from the “composite rate”.
Some of the dialysis community’s concerns prior to the release of the proposed rules were decided upon favorably by CMS. Those were namely a unit of payment on a per treatment basis. There was much discussion about it being paid out on a per week or per month allocation based upon 13 treatments per month. Also, there was talk about discontinuing the practice of allowing extra treatments justified by medical necessity. Both would have been problematic for home dialyzors. Fortunately, CMS has decided not to change either. We should praise CMS for making the right choice.
However, there are still some issues which remain that would benefit home dialysis. One major one is the cost of training. In the past a dialysis unit received $20 for each training session, and that was outside of the “composite rate”. That figure was already a mere drop in the bucket of what training costs. It’s estimated that the cost of a registered nurse alone is as high as $200 per training period. But CMS is proposing that training be part of the total bundled rate, which means the unit is to absorb the cost of training. It is feared that this would be a disincentive for some units to continue its home program. If this occurs, many current home dialyzors might lose their modality of choice.
Comment on the End Stage Renal Disease Prospective Payment System CMS has set up a 60 day window for interested parties to make comments regarding the ESRD PPS. The deadline for submitting comments is November 16th at 5:00 pm.
To view/download the Entire Action Plan including What Topics and Who to Contact, Please visit the following link:
NxStageUsers Home Dialysis Action Plan For Bundling
Thanks and we hope that you will write CMS about the upcoming Bundling
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