Dear Ms. Tavenner and Dr. Gilfillan:

On behalf of the undersigned organizations, thank you for your leadership of the Centers for Medicare and Medicaid Services (CMS) and the Center for Medicare and Medicaid Innovation (CMMI). Together, our organizations represent the patients, physicians, nurses, scientists, and other health professionals dedicated to advancing excellence in the care of patients with kidney disease. Foremost among our shared goals is continuous improvement in the quality, efficiency, and accessibility of care available to patients with kidney disease.

Our organizations applaud the Centers for Medicare and Medicaid Services (CMS) and the CMS Innovation Center’s establishment of the Comprehensive End Stage Renal Disease (ESRD) Care (CEC) Initiative. ESRD Seamless Care Organizations (ESCOs) present an exciting opportunity for the kidney care community to innovate in more patient-centered, coordinated ways to deliver kidney care and, ultimately, improve the lives of patients with kidney disease. We recognize and are grateful for your receptiveness to input from our organizations and other stakeholders in the kidney care community.

We also thank the Agency and the Innovation Center for addressing the concerns of the kidney care community by extending the deadline for submitting an application to August 1, 2013, and by reducing the minimum beneficiary threshold from 500 to 350 matched beneficiaries. The extension will allow many more nephrology practices, dialysis providers, and other Medicare providers to construct thoughtful, innovative proposals.

We write to request the opportunity for representatives from each of our organizations to meet jointly in-person with you or your staff after the August 1, 2013 application deadline. We wish to discuss how you envision the ESCO program moving forward based on the applications received, and to discuss our suggestions for strengthening the program in that context. Our organizations hope that our recommendations, outlined below in this communication, will be helpful as the CEC Initiative evolves in the coming months.

Our organizations appreciate CMS and the Innovation Center’s consideration of these recommendations, and look forward to the opportunity to hopefully discuss them in person later this summer. We believe that continued dialogue regarding the CEC Initiative will create the greatest chance of success for the program and for higher-quality care for patients on dialysis. An appendix to this letter includes contact information for each of our organizations.


American Association of Kidney Patients
American Kidney Fund
American Nephrology Nurses Association
American Society of Nephrology
American Society of Pediatric Nephrology
Dialysis Patient Citizens
Renal Physicians Association
Renal Support Network