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Many of you may have been following the discussions and policy making around Medicare’s “bundling” of dialysis reimbursement. However, even if you have not it is important to know how the changes in Medicare payments to dialysis clinics will impact the way patients receive care and how it could increase patients’ financial responsibilities.
Patients’ Guide to Medicare Reimbursement Changes
Medicare reimbursement for dialysis will change beginning January 1, 2011. About 90 percent of dialysis facilities have chosen to fully accept the new “bundled” payment system next year. These changes to Medicare payments for dialysis treatments are expected to impact the way you receive your dialysis care and could also have an impact on your out-of-pocket expenses. To help prepare you for these changes and empower you to take charge of your care under this new system, DPC has created the “Dialysis Patients’ Guide to the Medicare ESRD Bundle” brochure.
Final Rule on Medicare Payment for Dialysis: Changes Begin in 2011
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On July 24, the Centers for Medicare and Medicaid Services (CMS) released their final rule on how they will pay dialysis providers and what will be included in that bundled payment. CMS responded favorably to many of the comments DPC and other patient organizations submitted on their initial proposal. One such example is CMS created a list of lab tests that will be included in the bundled payment. Anything outside of this list will be paid for separately – allowing for non-dialysis related labs to be drawn in dialysis facilities. Another favorable outcome is the delay of including oral medications that do not have an injectable equivalent, such as phosphorous binders, in the bundle until 2014. This allows CMS to further study how including these medications will impact patients. Additionally, CMS added a separate payment for home dialysis training to encourage more providers to offer this option to patients. CMS also made a commitment to develop a monitoring system to track how changes in payment impact clinical practices and patients’ quality of care.
While the final rule is much better for patients than the initial proposed rule, there are still many areas where patients could have a greater financial responsibility or experience changes in the delivery of their care. Patients may begin noticing changes to their care and cost sharing as early as January 1, 2011. Every dialysis clinic will be required to fully operate under the new payment system beginning January 1, 2014.
> Read Medicare's Final Rule on the ESRD Bundle
Millions of Dollars Could be Lost for Dialysis Care
Medicare needs Congress’s help. CMS may have underestimated how many dialysis clinics will choose to fully use the new bundled payment in 2011. As a result, millions of dollars needed to treat patients on dialysis could be lost. On September 23, 2010 DPC Patient Ambassadors discussed the issue with their Members of Congress and provided them with the following letter.
>DPC Letter to Congress
On November 15, 2010 American Kidney Fund, Dialysis Patient Citizens, National Kidney Foundation and Renal Support Network sent a joint letter to Congress requesting a fix to the calculation of the transition adjuster that will be applied to the new bundled payment system in 2011.
>Patient Letter on Transition
DPC and Patients Influence the Development of the ESRD Bundle
Before issuing the final rule on the new ESRD Medicare prospective payment system (known as the ESRD bundle) CMS released a proposed rule on September 15, 2009, which outlined their initial plan for how the new system should work.
In an effort to improve the payment system for dialysis patients, DPC worked to educate patients on the CMS proposal and how it could change the way patients receive and pay for their dialysis care. We then asked for patients' feedback so we could properly represent, to CMS and Congress, the challenges patients would face under the Medicare payment system they had proposed.
Along with other kidney patient organizations, DPC called on CMS to ensure that the patients voice was heard, and we united again with patient organizations to encourage Members of Congress to support us in our efforts.
To further ensure our input was heard, our Executive Director Chad Lennox presented patient concerns and DPC recommendations live at a CMS town hall meeting. We then submitted formal written comments and recommendations to CMS on how to best modify their proposal to protect patients.
To amplify and strengthen our stance we joined with other coalitions to also submit formal comments to CMS
>Home Hemodialysis Workgroup Comment Letter
Former DPC Executive Director Chad Lennox commented in Renal Business Today on the patient impact of the proposed ESRD Bundle