On November 1, 2018, the Centers for Medicare & Medicaid Services (CMS) issued its final annual rule updating payment policies for the End-Stage Renal Disease (ESRD) Prospective Payment System and the ESRD Quality Incentive Program (QIP). Among new quality measures to take effect beginning in 2022 is Percentage of Prevalent Patients Placed on a Transplant Waiting List (PPPW). This measure was already scheduled to be reported for individual clinics, beginning next year, on CMS’ Dialysis Facility Compare website. Adding it to the QIP means that facilities can be penalized if the percentage of their patients waitlisted for transplant is below average.
The PPPW measure is controversial because it has not achieved consensus approval from the independent National Quality Forum. Many kidney care experts question whether dialysis clinics should be held accountable for transplant waitlisting since transplant centers decide whether a patient is eligible. However, Medicare does require clinics to inform their patients about the transplant process.