The Centers for Medicare & Medicaid Services (CMS) said the proposed changes mark the Innovation Center’s first direct effort to close health equity gaps.
CMS on Thursday issued a proposed rule to update the End-Stage Renal Disease (ESRD) Prospective Payment System (PPS) for calendar year (CY) 2022.
The proposal includes actions that aim to close health equity gaps by providing Medicare patients battling ESRD with greater access to care. It also makes changes to the ESRD Quality Incentive Program (QIP), modifies the ESRD Treatment Choices (ETC) Model, and updates ESRD PPS payment rates.
CMS said in an announcement that the planned changes to the ETC Model policies aim to encourage dialysis providers to decrease disparities in rates of home dialysis and kidney transplants among ESRD patients with lower socioeconomic status, making it the agency’s first CMS Innovation Center model to directly address health equity.
Disadvantaged Medicare patients suffer from ESRD at higher rates, according to CMS Office of Minority Health studies on racial, ethnic, and socioeconomic factors. They are also more likely to experience higher hospital readmissions and costs, as well as receive in-center hemodialysis because their kidneys are no longer able to function. Studies also indicate non-white ESRD patients are less likely to receive pre-ESRD kidney care, become waitlisted for a transplant, or receive a kidney transplant.
“Today’s proposed rule is grounded in measures to ensure people with Medicare who suffer from chronic kidney disease have easy access to quality care and convenient treatment options,” said CMS Administrator Chiquita Brooks-LaSure in the announcement. “When CMS encourages dialysis providers to offer more options for Medicare patients to receive dialysis treatments, it can be life changing and lead to better health outcomes, greater autonomy, and better quality of life for patients with kidney disease.”
The proposed changes to the ETC Model build on the current model by proposing to test a new health care approach that rewards ESRD facilities and managing clinicians participating in the model for achieving significant improvement in the rates of home dialysis and kidney transplants for lower income beneficiaries. If finalized, these changes would take effect Jan. 1, 2022.
The proposed rule also includes proposals under the ESRD Quality Incentive Program (ESRD QIP) to address the circumstances of the COVID-19 Public Health Emergency (PHE), such as not scoring or reducing payment to any facility in 2022 based on data from 2020.
Regarding COVID-19 vaccination measures, the proposed rule requests stakeholder feedback on the feasibility of incorporating COVID-19 Healthcare Provider and Patient Vaccination measures in the ESRD QIP measure set. Currently, nearly 90 percent of all dialysis facilities are reporting vaccination data performance to the Center for Disease Control and Prevention’s (CDC) National Healthcare Safety Network (NHSN). CMS is evaluating options for publicly reporting the data on official CMS datasets that compare the quality of care provided in Medicare-certified dialysis facilities nationwide.
CMS’ proposed rule includes several requests for information for the agency to consider as part of its goal to increase access to dialysis treatments at home. Currently, Medicare will only pay for dialysis at an ESRD facility for patients with Acute Kidney Injury (AKI). CMS is seeking comments regarding potentially modifying the site of renal dialysis services for patients with AKI and payment for AKI in the home setting.
CMS proposes a slight increase to the ESRD base rate. The proposed base payment rate for CY 2022 is $255.55, which increases the current base rate by $2.42. The agency projects that the updates for CY 2022 will increase the total payments to all ESRD facilities by 1.2 percent compared with CY 2021. CMS projects that hospital-based ESRD facilities will see a decrease in total payments of 1.3 percent, and freestanding facilities will see a projected increase in total payments of 1.2 percent.