Administrators ask CMS to delay ESRD Treatment Choices model
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The National Renal Administrators Association is asking CMS to delay the planned Jan. 1 launch of the ESRD Treatment Choices model until after the COVID-19 pandemic ends, giving dialysis providers time to prepare for the demonstration.
“I write to respectfully and urgently request delayed implementation of the ESRD Treatment Choices (ETC) Mandatory Model until after the COVID-19 Public Health Emergency concludes,” NRAA President Maria Regnier, RN, MSN, CNN, said in a letter to CMS Administrator Seema Verma. “Requiring ETC model participation for selected dialysis facilities that are working diligently and tirelessly to safely care for ESRD patients in the midst of the ongoing COVID-19 [public health emergency] PHE poses unnecessary risk and burden to these providers and the highly vulnerable patients they are caring for who are at serious risk for severe outcomes, including death, from COVID-19.”
CMS released the final rule of the ESRD Treatment Choices (ETC) payment model on Sept. 18 after delays in the launch of the program, which was to begin in January 2019. The demonstration, which runs through 2026, will test new financial incentives for increasing transplantation and getting more patients interested in home dialysis. CMS will randomly select 30% of the outpatient dialysis clinics in the United States through its Hospital Referral Regions to participate in the demonstration.
Regnier said in the letter that “costly and time-consuming structural changes to care practices necessary for successful participation in the ETC model is beyond what can reasonably be expected from dialysis facilities during the COVID-19 public health crisis – particularly for small and independent providers often times treating patients in rural and underserved communities. Moreover, although we are still analyzing the modifications made to the ETC model in the final rule, the NRAA continues to have a number of concerns with the Model that were finalized as proposed.”
Some of the concerns with the model, according to the letter, include the following:
- The association believes the ETC demonstration should exclude dialysis facilities owned by providers that have 35 clinics or less. “Data analysis performed by Dobson DaVanzo and Associates on behalf of the NRAA shows that low volume and rural ESRD facilities currently disproportionately do not offer home therapy relative to other facility types and, in many cases, are small and independent facilities with limited resources available to make the substantial up-front investment necessary to initiate and grow home therapy programs,” Regnier wrote. “Therefore, the NRAA continues to urge CMS to exclude dialysis facilities in organizations with 35 clinics or less from the ETC model.”
- The incentive being offered through the home dialysis payment adjustment (HDPA) in the ETC model is inadequate to support the initiation and growth of home therapy programs. “The model’s slight payment increase to support home dialysis simply is substantially outweighed by the significant upfront costs necessary to start and grow home therapy programs,” Regnier wrote in the letter. “Thus, the NRAA continues to urge CMS to significantly increase the HDPA amount so that providers with constrained resources and small or no home therapy programs can have at least some opportunity for successful participation in the model.”
Regnier said “a number of significant methodological issues remain unclear” and should be explained by CMS before the ETC model is implemented “so that participants have a much better understanding of the performance they need to achieve to avoid the model’s potentially substantial payment reductions (up to -10[%] for dialysis facilities).
“The NRAA respectfully makes these requests to advance our mutually shared goal of promoting the safe delivery of dialysis treatment to ESRD patients during the COVID-19 pandemic while at the same time ensuring these patients have more meaningful treatment choices that lead to better health outcomes and improved quality of life,” she said.
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