CMS proposes changes to ESRD Treatment Choices model to improve equity of care
Under a rule proposed by CMS, dialysis clinics in the ESRD Treatment Choices demonstration will receive higher payments if the centers direct more socially and economically disadvantaged patients to transplant or home dialysis.
The proposed changes, detailed in a 345-page filing available here, “would aim to encourage dialysis providers to decrease disparities in rates of home dialysis and kidney transplants among (end-stage renal disease) ESRD patients with lower socioeconomic status, making the model the agency’s first CMS Innovation Center model to directly address health equity,” CMS said in a press release.
The modifications are part of a larger proposed rule release by CMS on July 1 that includes an increase in the Medicare bundled payment for dialysis treatments and changes to the quality incentive program.
ETC model
Under the ETC model, which began January 1, participating dialysis facilities and clinicians who manage patients (managing clinicians) receive positive or negative adjustments on certain claims for dialysis and dialysis-related services, based on rates of home dialysis and transplantation among their beneficiaries.
The model includes two payment adjustments for clinics. The home dialysis payment adjustment is an upward adjustment on home dialysis and home dialysis-related claims in the initial 3 years of the demonstration. The second adjustment, the performance payment adjustment (PPA), creates upward or downward performance-based adjustment on all dialysis claims and monthly capitation payments to nephrology practices based on the participant’s performance on the ETC model’s home dialysis rate and transplant rate among the beneficiaries attributed to the ETC clinic.
The demonstration will end June 30, 2027.
Proposed changes
The payment adjustments proposed by CMS include the following:
- a health equity incentive to the improvement scoring methodology for both the home dialysis rate and the transplant rate. Dialysis clinics that demonstrate significant improvement in rates of home dialysis or transplantation among their beneficiaries who are dual-eligible for Medicare and Medicaid or low-income-subsidy (LIS) recipients could earn additional improvement points; and
- a re-stratification of achievement benchmarks by the proportion of beneficiaries who are dual-eligible for Medicare and Medicaid or are LIS recipients, so ETC clinics who see a high volume of these patients would not face negative financial consequences as a result.
“Taken together, these two proposed changes acknowledge that socioeconomic disparities in access to alternative renal replacement modalities exist and may impact the ability of ETC participants to perform well in the ETC model, while providing an incentive for all ETC participants to reduce such disparities among their Medicare patients,” CMS said in the release.
The agency said disadvantaged Medicare patients have ESRD at higher rates. “They are also more likely to experience higher hospital readmissions and costs, as well as receive in-center hemodialysis ... Studies also indicate ESRD patients [of color] are less likely to receive kidney care, become waitlisted for a transplant or receive a kidney transplant,” CMS said in the release
CMS is also soliciting feedback in the proposed rule on opportunities to collect and leverage diverse sets of data on race, ethnicity, Medicare/Medicaid dual eligibility status, disability status, LGBTQ+ and socioeconomic status. It also is interested in new methodological approaches to advance equity through the ESRD Quality Incentive Program.
Comments are due on the proposed changes to CMS by August 31.
References:
https://edit.cms.gov/newsroom/fact-sheets/end-stage-renal-disease-esrd-prospective-payment-system-pps-calendar-year-cy-2022-proposed-rule-cms
www.cms.gov/newsroom/fact-sheets/end-stage-renal-disease-esrd-prospective-payment-system-pps-calendar-year-cy-2022-proposed-rule-cms
www.federalregister.gov/public-inspection