On June 29, the Centers for Medicare & Medicaid Services (CMS) issued its proposed Annual Payment Rule for the End-Stage Renal Disease (ESRD) Program to govern dialysis services furnished beginning January 1, 2018. The proposed rule also makes minor changes to the ESRD Quality Incentive Program (QIP). This year’s rule includes an increase to the base rate, replacing QIP measures as well as including social risk factors in the QIP scores.
CMS says the ESRD proposed rule is “one of several rules for 2018 that reflect a broader Administration-wide strategy to relieve regulatory burdens for providers; support the patient-doctor relationship in healthcare; and promote transparency, flexibility, and innovation in the delivery of care.”
Update to the ESRD PPS base rate: The proposed 2018 base rate is $233.31, an increase of $1.76 to the current base rate of $231.55. CMS projects that the updates for 2018 will increase the total payments to all ESRD facilities by 0.8 percent compared with 2017. The update is in line with a statutory formula and recommendations from the Medicare Payment Advisory Commission.
ESRD QIP: The ESRD QIP is intended to promote high-quality care by dialysis facilities treating beneficiaries with ESRD. This program changed the way CMS pays for the treatment of ESRD patients by linking a portion of payment directly to facilities’ performance on quality measures. The ESRD QIP will reduce payments to ESRD facilities by up to 2 percent if they do not meet or exceed a minimum performance score.
Beginning in 2021, CMS proposes to replace “existing measures with new and improved measures.” Current measures address anemia management, dialysis adequacy, vascular access type, patient experience of care, infections, mineral metabolism management, safety, pain management, depression management, and hospital readmissions. CMS is proposing to remove the current Vascular Access Type clinical measures and replace them with new measures—Standard Fistula Rate and Long-Term Catheter Rate—that were recently endorsed by the National Quality Forum (NQF). NQF is a multi-stakeholder consensus standards organization of which DPC is a member. CMS is also proposing revisions to the Standardized Transfusion Ratio clinical measure so that the specifications for that measure are consistent with those endorsed by the NQF.
Including social risk factors in ESRD QIP: Last year, a federal report found that QIP scores are affected by socio-economic factors. For instance, the report found that dialysis clinics serving patients who are eligible for Medicaid as well as Medicare (“dual eligibles”) have lower scores on anemia management, fistula use, and catheter use. The report also found racial disparities in dialysis adequacy and fistula use measures. The study determined that clinics serving poorer patients are more likely to get the full 2% QIP penalty.
CMS is seeking comment on whether to account for social risk factors in the ESRD QIP and, if so, which social risk factors (examples of which could include dual eligibility/low-income subsidy, race and ethnicity, and geographic areas of residence) might be most appropriate for stratifying measure scores and/or potential risk adjustment of a particular measure.
Updates to the Performance Score Certificate (PSC): Beginning in 2019, CMS proposes to shorten the Performance Score Certificates (PSCs) posted in dialysis facilities “to make the document simpler and easier to understand.”