Transplant CoP Changes

Modifications to the Conditions of Participation for kidney transplant programs (formerly transplant centers) have been published in the Federal Register for September 30, 2019.  They will take effect on November 29, 2019.  The primary change is that an approved transplant program will no longer be required to submit outcome data for periodic re-approval.  The modifications are summarized by the American Society of Transplant Surgeons at https://asts.org/news-and-publications/asts-news/article/2019/09/27/cms-removes-outcomes-requirement-for-transplant-center-re-approval, and detailed in the Federal Register at https://www.govinfo.gov/content/pkg/FR-2019-09-30/pdf/2019-20736.pdf, pp.51748-50.

Notify Network of Emergencies

Winter is arriving early in some Network 16 locations, and CMS requires all ESRD Networks to track the status of facility operations, and patient access to treatment, during emergency events at all facilities.  If the operations of your facility, or ability for patients to have access to dialysis, are impacted by emergency events, please let your Network know right away.

  • For Washington, Oregon, Idaho, Montana, and Alaska (Network 16), contact Lisa Hall at 206-923-0714, or by email at LHall@nw16.esrd.net.  We also ask that you fill out and submit the Network Disaster Reporting Form at http://www.esrdnetwork18.org/machform/view.php?id=44393 (Network 18 will forward it back to Network 16).

You are reminded never to put PHI or PII in an email or online form.  Examples include patient name or initials, birthdate, SSN, and other identifying information.

Notify Network of Emergencies

Wildfire season is here, and CMS requires all ESRD Networks to track the status of facility operations, and patient access to treatment, during emergency events at all facilities.  If the operations of your facility, or ability for patients to have access to dialysis, are impacted by emergency events, please let your Network know right away.

You are reminded never to put PHI or PII in an email or online form.  Examples include patient name or initials, birthdate, SSN, and other identifying information.

New CMS Transplant Center Survey Protocol Manual

CMS has added a new Appendix X to their State Operations Manual, detailing Interpretive Guidance and Survey Protocols for Organ Transplant Program Conditions for Participation, effective May 24, 2019.  Find a copy at https://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/2019Downloads/R189SOMA.pdf.

NW16 New Form for Reporting IVD

We’ve established a new form for Network 16 facilities to report Involuntary Discharge or Transfer.  Find the form and instructions for using it at https://www.nwrn.org/providers-and-professional-staff/patient-services/ivd.html.

The Conditions for Coverage (CfC) require all facilities to notify both the Network and your State Survey Agency, within specified time parameters, of all involuntary discharges and transfers.  Better yet, if you’re considering an involuntary discharge or transfer, first contact the Network Patient Services Coordinator, Lisa Hall (lhall@nw16.esrd.net or 206-923-0714), to help you negotiate a better outcome.

For Network 18 facilities, see http://www.esrdnetwork18.org/providers/patient-services/.

Disaster Notifications

CMS requires Networks to track the status of facility operations and patient access to treatment during emergency events like the recent major earthquake in Alaska.  If the operations of your facility, or ability for patients to have access to dialysis are impacted by emergency events, please let your Network know right away.

Find requirements and recommendations on earthquake preparedness for patients and providers at:

~11/20 CMS Proposed Rule on Regulatory Reduction

CMS is seeking public comment on a Proposed Rule for Medicare and Medicaid Programs; Regulatory Provisions to Promote Program Efficiency, Transparency, and Burden Reduction.  Comments will be due sixty days after the Proposed Rule is published in the Federal Register, probably around November 20, 2018.  A pre-publication copy of the Proposed Rule can be found at https://s3.amazonaws.com/public-inspection.federalregister.gov/2018-19599.pdf.  A quick and not exhaustive scan of the Proposal finds matters relevant to Transplant Centers at p.13, pp.69ff, 129ff, 183ff, 243ff, and 274ff, and matters relevant to Dialysis Facilities at pp.85-86, p.101, pp.104ff, 110-111, 142ff, 203ff, 217ff, and 281ff.