CMS Publishes ETC Payment Model

CMS has released information about the long-awaited ESRD Treatment Choices (ETC) Model, which “aims to test whether greater use of home dialysis and kidney transplantation for Medicare beneficiaries with ESRD will reduce Medicare expenditures, while preserving or enhancing the quality of care furnished to beneficiaries with ESRD.”  The newly published information includes:

CROWNWeb Deadlines Stopwatch

CROWNWeb has created a Data Submission Stopwatch as a graphic reminder of when information must be submitted to CMS.  Download the Stopwatch from https://mycrownweb.org/wp-content/uploads/2018/03/Stopwatch-560×380.jpg.  Each of the items on the Stopwatch must to be submitted within the time frame shown, as per the ESRD Systems Data Management Guidelines.  Download the Guidelines from https://mycrownweb.org/assets/documents/ESRD_Systems_Data_Management_Guidelines.pdf.

CMS QIP CY2021 Proposed Rule Webinar

CMS has posted a webinar on the QIP CY2021 Proposed Rule (see https://nwrnbulletins.wordpress.com/2020/07/10/9-4-comments-due-re-proposed-changes-to-qip/).  Find a PDF of the presentation slides, an audio recording, and a PDF of the transcript of the webinar at https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/ESRDQIP/99_EduResources.

8/31 PY2021 QIP Preview Period Ends

In a call with the Networks, CMS has indicated that the ESRD QIP Preview Period for PY2021 will run from July 29, 2020 to 11:59 pm PDT August 31, 2020 (which is 10:59 pm AKDT August 31, 2020, and 12:59 am MDT September 1, 2020), superseding a previously indicated date range of July 15-August 17.  CMS has also indicated that the previous limit of one Formal Inquiry per CCN has been relaxed – there is no longer any limit on the number of Formal Inquiries a facility can submit.  The advice to submit them early enough to allow CMS to respond, and you to reply, before August 31 is presumably still in effect.

9/4 Comments Due re Proposed Changes to QIP

CMS has presented for publication in the Federal Register a new proposed rule on changes to the ESRD PPS/QIP.  Public Comment must be received by September 4, 2020.  “In addition to the annual technical updates for the ESRD PPS, the proposed rule proposes the following:

  • “An addition to the ESRD PPS base rate to include calcimimetics in the ESRD PPS bundled payment;
  • “Changes to the eligibility criteria and determination process for the transitional add-on payment adjustment for new and innovative equipment and supplies (TPNIES);
  • “The expansion of the TPNIES to include new and innovative capital-related assets that are home dialysis machines;
  • “A change to the low-volume adjustment eligibility criteria and attestation requirement to account for the COVID-19 PHE;
  • “An update to the ESRD PPS wage index to adopt the new OMB delineations with a transition period. …
  • “The following updates to the ESRD QIP:
    • “Scoring methodology changes to the UFR reporting measure;
    • “Updates to the NHSN validation study.”
  • “This proposed rule also provides information received from two manufacturers whose products, a dialyzer and a cartridge for a home dialysis machine, are being considered for TPNIES in CY 2021.”

The (slightly edited) quotations are from the ESRD PPS CY2021 Proposed Rule Fact Sheet (CMS-1732-P) at https://www.cms.gov/newsroom/fact-sheets/end-stage-renal-disease-esrd-prospective-payment-system-pps-calendar-year-cy-2021-proposed-rule-cms.  Find the Federal Register entry, which is scheduled to be published on July 13, 2020, at https://www.federalregister.gov/documents/2020/07/13/2020-14671/medicare-program-end-stage-renal-disease-prospective-payment-system-payment-for-renal-dialysis.

7/8+ CMS PY2021 DFR/QIP Webinar

CMS has scheduled a webinar on the PY2021 ESRD DFR/QIP process.  We haven’t seen a timeline yet for the process, though there are rumors that the DFR data has become available.

The webinar is titled ESRD QIP: Previewing Your Facility’s PY2021 Performance Data.  There are three sessions, each repeating the same material, so you need to attend only one of them.  To register:

    • July 8, 2020, 11am PDT – Click here.
    • July 14, 2020, 11am PDT – Click here.
    • July 23, 2020, 11am PDT – Click here.

After you register, you will receive an e-mail containing a unique webinar link and audio details.  Do not share the link, as it will be unique to you.  If more than one staff member at your facility would like to attend, and you can maintain safe social distancing, you may join as a team.  The webinar will cover:

    • How to access and review your facility’s PSR and PLR.
    • How CMS calculated your QIP performance scores.
    • What your TPS means to your facility’s 2021 reimbursement.
    • When and where to ask questions.
    • Where to get help and additional information.

To learn more about the QIP and DFR (and DFC) Preview process, see https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/ESRDQIP/.  It’s not updated for PY2021 yet, but will be soon.

For more information on the PY2021 process, see https://mycrownweb.org/2020/06/py-2021-esrd-qip-preview-period-webinar/.  If you haven’t already made the conversion, note that you will need to use the new QIP User Interface in the updated version of EQRS; for details and instructions see https://mycrownweb.org/2020/06/esrd-qip-ui-phase1/.

For further assistance and to ask questions, use the CMS Quality Support ServiceNow Q&A Tool at https://cmsqualitysupport.servicenowservices.com/qnet_qa.

COVID-19 Adjustments to CMS Alternate Payment Models

CMS has published a web page on CMS Innovation Center COVID-19 Flexibilities detailing current and future changes to their proposed alternate payment models (Comprehensive ESRD Care, Kidney Care Choices) as a result of COVID-19.  Find the page at https://innovation.cms.gov/innovation-models/covid-19-flexibilities.

ASN KidneyNewsOnline also has an article on the subject, Significant Update from CMS on Voluntary Models and ESCOs Including Q&A, at https://www.kidneynews.org/policy-advocacy/leading-edge/significant-update-from-cms-on-voluntary-models-and-escos-including-qa.

HDC on Safe Social Work and COVID-19

Home Dialysis Central has published a blog post on Dialysis Social Work During a Pandemic: Caring for Patients Safely, thoroughly reviewing what are permitted and required by:

  • CMS Conditions for Coverage,
  • Social Work licenses and training,
  • Medicare reimbursement rules and waivers,
  • Patient and staff safety,
  • Home dialysis,
  • Effective communication,
  • PPE,
  • Telehealth,
  • Comparative advantage,

all in the context of the COVID-19 pandemic.  Find the post at https://homedialysis.org/news-and-research/blog/361-dialysis-social-work-during-a-pandemic-caring-for-patients-safely.

CMS Video: Telehealth Coverage, Payment, Billing

CMS has released a video providing answers to common questions about the Medicare telehealth services benefit coverage, payment, and billing.  CMS is expanding this benefit on a temporary and emergency basis under the 1135 waiver authority and Coronavirus Preparedness and Response Supplemental Appropriations Act.  Find the video at https://www.youtube.com/watch?v=bdb9NKtybzo.

CMS: Relief from QIP Reporting

On March 22, 2020 CMS announced relief from QIP-related reporting requirements for CROWNWeb and the ESRD QIP.   Find the full CMS press release at https://www.cms.gov/newsroom/press-releases/cms-announces-relief-clinicians-providers-hospitals-and-facilities-participating-quality-reporting.  An excerpt follows:

“CMS will not count data from January 1, 2020 through June 30, 2020 (Q1-Q2) for performance or payment programs.  Data does not need to be submitted to CMS for this time period…  No data reflecting services provided January 1, 2020 through June 30, 2020 will be used in CMS’s calculations for the Medicare quality reporting… programs.  This is being done to reduce the data collection and reporting burden on providers responding to the COVID-19 pandemic.”

CMS published an additional bulletin on March 27, https://www.cms.gov/files/document/guidance-memo-exceptions-and-extensions-quality-reporting-and-value-based-purchasing-programs.pdf, with ESRD information on pp.9-10.  This bulletin clarifies the original and includes new information on NHSN QIP relief, and information on opting out of the relief:

“Dialysis facilities should be aware of the potential subsequent impact to a facility’s total performance score (TPS) when data are excluded from score calculations.  Facilities impacted by COVID-19 may elect to opt out of the CMS granted exception by emailing the request to the ESRD QIP at esrdqip@cms.hhs.gov.  The email must be sent by the dialysis facility’s chief executive officer (CEO) or designee.  We are requesting that a dialysis facility make this request within 90 days of March 22, 2020.  For further assistance regarding the ESRD QIP information contained in this message, please contact the ESRD QIP at esrdqip@cms.hhs.gov.”