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DPC Comments on Threat to Vascular Access Centers

2020-03-21T20:42:26+00:00September 19th, 2018|Categories: Article, Comment Letter, Dialysis Funding, Improve Access to Care|

The Centers for Medicaid Services (CMS) is proposing to cut reimbursement for vascular access centers. This could negatively impact dialysis patents’ access to care, which is why we have weighed in on this important issue. Dialysis Access and Fistulas People with kidney failure need to have a dialysis access placed in order to receive live-saving dialysis treatments. Vascular surgeons create and maintain arteriovenous fistulas, which is a type of dialysis access. Fistulas are important for individuals on dialysis as they are considered a best practice in kidney care, improve patient outcomes and reduce the risk of infection. Read DPC’s comment letter [...]

DPC Comments on Annual Medicare ESRD Rule

2020-03-21T20:42:26+00:00August 29th, 2018|Categories: Comment Letter, Innovation, Quality Incentive Program|

Dialysis Patient Citizens sent its comment letter to the Centers for Medicare & Medicaid Services (CMS) expressing concerns and providing feedback on its End-Stage Renal Disease Prospective Payment System and Quality Incentive Program proposed payment rule (CMS-1691-P). The letter was informed by results from Dialysis Patient Citizen’s 2018 membership survey and focused on the following areas: Quality incentive program and the meaningful measures framework Transitional drug add-on payment adjustment and payments to reward innovation Request for information on price transparency Our hope is that by addressing these important topics, CMS will make amendments to the rule that will ultimately lead [...]

DPC Supports Improved Access to Private Insurance for Patients

2022-08-05T22:11:25+00:00August 22nd, 2018|Categories: Access to Transplant, Article, Comment Letter, Dental Coverage, Private Insurance Coverage|Tags: |

Currently, dialysis patients are restricted to 30 months on private insurance coverage before having to go into Medicare. The House of Representatives recently proposed extending this length of time by three months, which is estimated to save Medicare $344 million. Access to private insurance is critical for dialysis patients, and we are very appreciative of the House’s efforts to improve that access. Read our letter below in support of this proposal: Dear Leader McConnell, Minority Leader Schumer, Chairman Hatch, and Ranking Member Wyden: As America’s largest patient-led kidney disease organization representing over 30,000 dialysis patients and family members, Dialysis Patient [...]

DPC Submits Comments on Market Stabilization

2020-03-21T20:43:09+00:00March 9th, 2017|Categories: Comment Letter, Transportation Services|

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 [...]

Re: CMS-3337-IFC: Medicare Program; Conditions for Coverage for End-Stage Renal Disease Facilities—Third Party Payment

2020-03-21T20:43:10+00:00January 10th, 2017|Categories: Charitable Premium Assistance, Comment Letter|

Re: CMS-3337-IFC: Medicare Program; Conditions for Coverage for End-Stage Renal Disease Facilities--Third Party Payment To whom it may concern: Dialysis Patient Citizens (DPC) writes to offer its comments on the above referenced interim final rule. We are requesting that the Agency withdraw the rule and follow the notice-and-comment rulemaking process prescribed by the Administrative Procedures Act (APA). We explain below why this unusual regulatory action reached an incorrect result. DPC's membership is restricted to kidney disease patients and their family members. We have more than 28,000 total members. DPC is a patient-led organization. Its by-laws require that the President, Vice [...]

Patient Group Comments to CMS re: Request for Information on Insurance Steering

2020-03-21T20:44:12+00:00September 22nd, 2016|Categories: Charitable Premium Assistance, Comment Letter|

Andy Slavitt Acting Administrator Centers for Medicare & Medicaid Services Department of Health and Human Services 200 Independence Avenue, SW Washington, DC 20201 RE: CMS-6074-NC: “Inappropriate Steering of Individuals Eligible for or Receiving Medicare and Medicaid Benefits to Individual Market Plans” Dear Acting Administrator Slavitt: On behalf of the dialysis patients we represent, the American Kidney Fund (AKF), Dialysis Patient Citizens (DPC), and the National Kidney Foundation (NKF) appreciate the opportunity to provide comments on the Request for Information entitled “Inappropriate Steering of Individuals Eligible for or Receiving Medicare and Medicaid Benefits to Individual Market Plans” (RFI). More specifically, we are [...]

Comments to CMS re: Request for Information on Insurance Steering

2020-03-21T20:44:12+00:00September 20th, 2016|Categories: Charitable Premium Assistance, Comment Letter, Innovation|

Andrew Slavitt, Acting Administrator Centers for Medicare and Medicaid Services Department of Health and Human Services Hubert H. Humphrey Building 200 Independence Avenue, SW Washington, D.C. 20201 Re: CMS-6074-NC: “Request for Information: Inappropriate Steering of Individuals Eligible for or Receiving Medicare and Medicaid Benefits” Dear Mr. Slavitt: Dialysis Patient Citizens (DPC) responds herein to the Centers for Medicare and Medicaid Services (CMS) with comments on the above referenced Request for Information. As America’s largest patient-led organization representing dialysis patients, DPC’s membership consists of more than 28,000 dialysis and pre-dialysis patients and their families. We seek to ensure the patient point [...]

CMS-1651-P, Prospective Payment System and QIP

2020-11-25T21:20:29+00:00August 23rd, 2016|Categories: Comment Letter, Quality Incentive Program|

Andrew Slavitt, Acting Administrator Centers for Medicare and Medicaid Services Department of Health and Human Services Hubert H. Humphrey Building 200 Independence Avenue, SW Washington, D.C. 20201 Re: CMS-1651-P: End-Stage Renal Disease Prospective Payment System, Quality Incentive Program Dear Mr. Slavitt: Dialysis Patient Citizens (DPC) appreciates the opportunity to provide the Centers for Medicare and Medicaid Services (CMS) with comments on the proposed payment rule for the Medicare End Stage Renal Disease (ESRD) program. As America’s largest patient-led organization representing dialysis patients, DPC’s membership consists of more than 28,000 dialysis and pre-dialysis patients and their families. We seek to ensure [...]

DPC Complaint to OFM re: Washington State Insurance Plans

2022-08-05T22:12:59+00:00July 19th, 2016|Categories: Charitable Premium Assistance, Comment Letter, Innovation, Private Insurance Coverage, State Advocacy|

Re: Violations of the Medicare Secondary Payer Statute, 42 U.S.C. § 1395y(b), by Washington State Health Insurance Plans Dear Ms. Parker and Ms. Dotzel: We write to bring to your attention the fact that at least three group insurers in the state of Washington are offering large plans with provisions that violate the explicit terms of the Medicare Secondary Payer Statute. These violations not only potentially subject the insurers to statutory civil monetary penalties, but render these insurers’ plans nonconforming under applicable regulations. As America's largest patient-led organization representing 29,000 dialysis patients and family members, Dialysis Patient Citizens (DPC) strives to [...]

DPC Complaint to Department of Labor re: Insurance Plan Discrimination

2022-08-05T22:14:28+00:00June 28th, 2016|Categories: Charitable Premium Assistance, Comment Letter, Innovation, Private Insurance Coverage|

The Honorable Phyllis C. Borzi Assistant Secretary Employee Benefits Security Administration United States Department of Labor 200 Constitution Ave NW Washington, DC 20210 Re: Violations of Part 7 of the Employee Retirement Income Security Act Relating to Health Plans’ Treatment of End-Stage Renal Disease Dear Assistant Secretary Borzi: On behalf of the 29,000 dialysis patients and family members that we serve, Dialysis Patient Citizens (DPC) asks that the Employee Benefits Security Administration (EBSA) investigate activities some group health plans have undertaken that we believe discriminate against individuals with kidney failure in violation of Part 7 of the Employee Retirement Income Security [...]

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