Thank you for posting this. Regarding the performance standard, how is it calculated? How many testing samples are taken per month? Is it taken as an average for each patient and that 98% of the patients in each facility has to have an average hemoglobin over 10g/dL each month?
It is also interesting that hemodialysis adequacy for homedialysis patients are not included in the calculation of ESRD QIP (End-Stage Renal Disease Quality Incentive Program).
http://www.federalregister.gov/articles/2011/01/05/2010-33143/medicare-program-end-stage-renal-disease-quality-incentive-program#p-84Comment: One commenter noted that the proposed initial performance standard based on the
2008 national performance rate of two percent for the Hemoglobin Less Than 10g/dL measure would be extremely difficult for providers/facilities to meet and would likely lead to overuse of ESAs. The commenter noted that the 2008 data reflects practices that were furnished prior to recent studies and FDA warnings regarding the danger of high hemoglobin levels, and that at the time, providers/facilities were unaware of the danger of high hemoglobin levels. Additionally, the commenter suggested setting the initial performance standards for the anemia management measures at 10 percent for Hemoglobin Less than 10g/dL and Hemoglobin Greater than 12g/dL.Show citation box
Response: We disagree with the commenter's suggestion that the anemia management measures performance standards should be set at 10 percent. We have made providers/facilities aware of the dangers of high hemoglobin levels related to use of ESAs since as early as 2005, when we changed our policy regarding ESAs and the monitoring of high hemoglobin levels (see CMS Manual System, Pub 100-04 Medicare Claims Processing, Transmittal 751 (November 10, 2005)). Since that time and with the release of the FDA guidelines in 2008, the historical data demonstrate that the number of patients with high hemoglobin levels has decreased and the number of patients with Hemoglobin Less than 10 g/dL has not increased. We believe that lowering the standard to 10 percent does not move quality forward.
Comment: One commenter requested that the initial performance standard for the hemodialysis adequacy measure be recalculated to reflect that home hemodialysis patients are excluded from the measure.Show citation box
Response: As stated in the ESRD PPS final rule (75 FR 49186), home hemodialysis patients are not part of the measure population for the hemodialysis adequacy measure for purposes of the ESRD QIP. Therefore,
home hemodialysis patients will not be included in the measure calculation.Show citation box
After consideration of the public comments, we are finalizing the performance standards as proposed.
I Hate Dialysis Message Board
Author
