A recent proposed rule released by the Centers for Medicare & Medicaid Services (CMS) provided guidance for market stabilization of the Affordable Care Act. Within this proposed rule, network adequacy provisions for dialysis clinics provided a narrow scope for insurers. In comments submitted by DPC on March 6, we argued stronger time and distance criteria need to be added to these provisions.
Research shows there is little difference between living in a metropolitan area compared to living in a rural environment, but there are significant mortality risks associated with actual distance from a dialysis facility. Additionally, after only 15 minutes of travel time, morbidity and mortality rates increased while treatment adherence decreased.
As insurers look to create narrower networks, maintaining loose standards for adequacy will discourage patient enrollment. If a patient is required to drive past a closer facility in order to go to an in-network facility, they will have no choice but to drop or refrain from enrolling in the plan. Weaker standards could be another way for insurers’ to exclude ESRD patients from enrollment.
We hope to see a revised rule with stricter network adequacy requirements and will continue to ensure dialysis patients have adequate access to care.
Read DPC’s complete comment letter here.