HDC Blog Post re Patient Power

Home Dialysis Central has published a new blog post on The Power of the Patient Voice that cites many examples of how influential the voices of patients have been in CMS policies and regulations, especially those around home dialysis.  Find the post at https://homedialysis.org/news-and-research/blog/369-the-power-of-the-patient-voice.  In it they mention the ESRD PPS Proposed Rule on Medicare coverage and regulations that CMS publishes every year, and that Home Dialyzors United will next month remind all dialysis patients of your right to comment, and how to do it.  If you’d like to read ahead, find a link to the 2021 PPS Proposed Rule at https://nwrnbulletins.wordpress.com/2020/07/10/9-4-comments-due-re-proposed-changes-to-qip/.

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.

UM-KECC Survey: Life Goals and Care Team

The University of Michigan KECC is conducting an ESRD Patient Reported Outcomes Quality Initiative Project Patient Life Goals Study, and seeks dialysis patients at least 18 years old to answer a new Survey that asks about your individual life goals and your dialysis facility care team.  Life goals are personal goals that you think are important to achieve, such as having the ability to go to work, go to school, travel, or spend time with family.  The Study aims to improve the odds that your care team will consider your individual life goals in the treatment planning process.  Find an introductory letter and the Survey at https://redcapproduction.umms.med.umich.edu/surveys/index.php?s=DT4N3P48AC.  There’s an easy-to-miss check box at the bottom of this page, which you have to check before the Survey questions appear.  The Survey doesn’t seem to specify an expiration date.

6/1 Comments Due on CMS Flexibility Rules Change

CMS has published an Interim Final Rule with Comment Period on the Flexibility changes in Medicare rules made on March 31, 2020.  The Comment Period will expire June 1, 2020.  For details and comment see Medicare and Medicaid Programs: Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency at https://www.regulations.gov/document?D=CMS-2020-0032-0013.

AAKP Coronavirus Survey

AAKP is asking dialysis patients to take a survey on their experience with and concerns about COVID-19.  AAKP’s introduction follows:

“AAKP works closely and constructively with Federal and state officials on health issues of concern to both the general public and those who are immunocompromised – like kidney patients.  As we have in the past with flu and vaccines, we are interested in relaying your insights about the Coronavirus to relevant officials so that their actions and communications are better informed and responsive to your concerns.  As a dialysis patient, has the Coronavirus impacted your thinking or behavior?  What communication, if any, have you, as a dialysis patient, received with your healthcare team and/or dialysis facility?  TAKE A FEW MINUTES, TELL US YOUR THOUGHTS!  AAKP will share insights gleaned from you with the brave medical and scientific professionals fighting the Coronavirus! … Answers and any comments provided will not be attributed to any individual – the FLASH SURVEY is completely anonymous.”

Find the survey at https://www.surveymonkey.com/r/DialysisandCoronavirus.  They do not indicate how long the survey will be available.

2/21 CMS Proposed Rule on OPO Measures Comment Period

In December CMS proposed revisions to Organ Procurement Organization Performance Measures for Kidney Donation Rate and Transplant Rate, and to OPO monitoring and benchmarking.  The revised measures aim to increase the number of Kidney Transplants by about 5,000 per year.  The revisions are described in the Fact Sheet at https://www.cms.gov/newsroom/fact-sheets/organ-procurement-organization-opo-conditions-coverage-proposed-rule-revisions-outcome-measures-opos.  Public Comment is due by February 21, 2020.  The Proposed Rule is published in the Federal Register at https://www.federalregister.gov/documents/2019/12/23/2019-27418/medicare-and-medicaid-programs-organ-procurement-organizations-conditions-for-coverage-revisions-to.

9/12 UM-KECC Seeks Volunteers to Test Questionnaire

The University of Michigan Kidney Epidemiology and Cost Center, under contract to CMS, is seeking dialysis patient and facility staff volunteers to provide feedback, via a half-hour phone call, on a draft of a short self-report questionnaire on patient life goals.  They seek both patients with experience on HD, PD, or HHD, and clinical staff (nephrologists, nurses, dieticians, social workers).  Those interested are asked to send a one-paragraph statement describing your interest and experience, to dialysisdata@umich.edu by September 12, 2019.

NW18 8/9 POLST Survey

The Coalition for Compassionate Care of California is conducting a survey to better understand the level of interest and engagement in a state-wide electronic Registry of Physician Orders for Life-Sustaining Treatment (POLST).  POLST is a form that gives seriously-ill patients more control over their end-of-life care, including medical treatment, extraordinary measures (such as a ventilator or feeding tube) and CPR.  Printed on bright pink paper, and signed by both a patient and physician, nurse practitioner or physician assistant, POLST can prevent unwanted or ineffective treatments, reduce patient and family suffering, and ensure that a patient’s wishes are honored.  Since it’s designed to be readily available to all healthcare practitioners in any setting or circumstance, electronic availability would promote its purpose.  For more information and a sample of the California form, see https://capolst.org/.  Take the survey, if possible before August 9, 2019, at https://www.surveymonkey.com/r/3XC2PGX.

9/16 CMS ETC Payment Model Comments Due

Home Dialysis Central has posted a thorough review of the proposed new ESRD reimbursement models discussed at https://nwrnbulletins.wordpress.com/2019/07/12/new-cms-payment-models/.  Find the review at https://homedialysis.org/news-and-research/blog/318-what-the-em-advancing-american-kidney-health-initiative-em-aakhi-executive-order-may-mean-for-you.

The ETC payment model has been published in the Federal Register, and public comments are due by September 16, 2019.  Find the Notice at https://www.federalregister.gov/documents/2019/07/18/2019-14902/medicare-program-specialty-care-models-to-improve-quality-of-care-and-reduce-expenditures.  The Executive Order that triggered the new payment models is published at https://www.federalregister.gov/documents/2019/07/15/2019-15159/advancing-american-kidney-health.

8/12 CMS RFI on Patients over Paperwork

CMS is requesting public comment on future phases of their Patients over Paperwork program, with comments due by August 12, 2019.  Find the Federal Register notice at https://www.federalregister.gov/documents/2019/06/11/2019-12215/request-for-information-reducing-administrative-burden-to-put-patients-over-paperwork.  The CMS Patients over Paperwork web page is at https://www.cms.gov/about-cms/story-page/patients-over-paperwork.html, and a press release on the RFI at https://www.cms.gov/newsroom/press-releases/cms-seeks-public-input-patients-over-paperwork-initiative-further-reduce-administrative-regulatory.