DPC has filed its letter commenting on this year’s Medicare ESRD Proposed Rule, which governs payments to dialysis facilities. The Centers for Medicare & Medicaid Services (CMS) heralded this year’s payment rules as undertaking new initiatives to reduce health disparities. DPC’s letter critiques these initiatives as insufficient and endorses alternative approaches.

CMS is proposing to collect new data on racial disparities, and to stratify quality measures so that facilities serving disadvantaged patients no longer receive QIP payment reductions simply because patients are poor. DPC endorses these moves, but points to recent calls by experts to address disparities by supplementing payments to clinics that serve disadvantaged populations. DPC calls for a Social Needs Payment Supplement that would add resources in such clinics.

CMS also proposes to modify its demonstration project promoting home dialysis and kidney transplants, to give extra rewards to nephrologists and clinics when poorer patients switch modalities. DPC criticized this as a half-measure because it adds no new resources to help these patients. DPC continues to advocate Medicare coverage of medical necessary dental care for transplant candidates, and compensation of the full costs to living organ donors, as two initiatives that would promote both health equity. DPC also favors a demonstration of staff-assisted home dialysis to improve uptake among disadvantaged patients.