Kidney care community offers suggestions to mitigate Kidney Care Choices model delay
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Professional organizations had mixed responses to the delay of the Kidney Care Choices payment model but offered suggestions to limit the impact of the delay on patient care and to improve the model when it is implemented.
CMS announced on its website that the model’s first performance year, which was set to begin in April, will instead begin in January 2022.
Reduce the impact of the delay
In a letter to Shalon Quinn, PhD, MPH, director of the division of kidney health at CMS, and Elizabeth Fowler, JD, PhD, deputy administrator and director of the Center for Medicare and Medicaid Innovation (CMMI), members of the Forum of End Stage Renal Disease (ESRD) Networks leadership, including Kam Kalantar-Zadeh, MD, MPH, PhD, Ralph Atkinson III, MD, David E. Henner, DO, and Andrew Howard, MD, FACP, said the postponement created an “unplanned and delayed entry” to CMS’s merit-based incentive payment system (MIPS) for many health care providers, which they wrote “will present yet another unexpected burden to the delivery of patient-centered care to our vulnerable population.”
The letter called ESRD Seamless Care Organizations (ESCO) model “an excellent first step” and suggested CMS extend it until the end of 2021. ESCOs are part of the CMS Comprehensive ESRD Care model that ran from 2015 through 2020, according to the CMS website.
The Renal Physicians’ Association (RPA) offered several suggestions to mitigate the financial impact on practices caused by the delay, stating in a letter to Fowler that it heard from “dozens of nephrology practices who are exceptionally frustrated by not only the delay but what it means for their involvement in CMS quality measurement activities.”
The RPA said that CMS should do the following:
- automatically qualify applicants with Kidney Care Choices (KCC) model period participation agreements for MIPS hardship exception;
- allow applicants who would have transitioned from the ESCO model to the KCC model to participate in ESCO through the end of the first quarter “to fulfill their [Medicare Access and CHIP Reauthorization Act] MACRA/Advanced Alternate Payment Models requirement;” and
- ensure ESCOs will receive the MACRA bonus for 2 years “since CMMI’s decision eliminates one of the [2] years that would have otherwise been available.”
Improve the KCC model
The American Society of Nephrology echoed the importance of reducing the financial impact on practices. The organization announced online that it told CMMI that “the agency’s top priority must be to deal with those nephrologists” who are impacted by the delay and consider “how will they be impacted financially.” The announcement said that CMMI would have a response “within a matter of weeks.”
The ASN also pointed out that the delay could improve care in the long-term, despite the short-term disruption, by addressing aspects of the KCC model.
“While disappointed that implementation of the KCC model has been extended, we ultimately think the additional time will allow CMMI to address some known, fixable challenges with the model, ensuring greater nephrologist participation and the success of the model when it does launch,” Rachel Meyer, senior director of policy and government affairs at ASN, said in the announcement.
The ASN addressed those challenges in a letter to Fowler. Scott E. Bieber, DO, chair of the ASN’s quality committee, wrote in the letter that some of these issues could limit the ability of practices and patients to participate.
For practices, certain provisions would affect cash flow, including the “[w]ithholding [of] 30 [%] of payments” and the transplant bonus being “paid over [3] years,” according to the letter. Although patient participation “is key to the model’s success,” Bieber also said “[r]emoving the facility fee will negatively impact the ability of some groups to participate.” The letter also raised concerns related to administering the patient activation measure and improving scores, as well as “the payment levels of the CKD quarterly capitated payment.”
“The payment pathways of the KCC model are vitally important steps to improving kidney care, but ASN believes the above issues must be addressed for the program to have a chance at success,” Beiber wrote.
References:
- Comprehensive ESRD Care Model. CMS. Accessed March 17, 2021. Available at: https://innovation.cms.gov/innovation-models/comprehensive-esrd-care.
- Important Update for Nephrologists re: MIPS. Kidney News Online. Accessed March 17, 2021. Available at: https://www.kidneynews.org/policy-advocacy/leading-edge/important-update-for-nephrologists-re-mips.
- Kidney Care Choices (KCC) Model. CMS. Accessed March 17, 2021. Available at: https://innovation.cms.gov/innovation-models/kidney-care-choices-kcc-model.
- RPA’s Response to CMMI Delay of KCC Payment Models. Renal Physician Association. Accessed March 18, 2021. Available at: https://cdn.ymaws.com/www.renalmd.org/resource/resmgr/legregscomp/federal_agencies/ltr_to_kcc_delay_final_3-202.pdf.
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