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March 17, 2022
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ANNA: Plan for non-nursing staff, industry to conduct home dialysis training ‘dangerous’

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The American Nephrology Nurses Association is criticizing a position paper released by a kidney community advocacy group that is proposing non-nursing personnel and dialysis manufacturers provide home dialysis training.

Dave Walz

“We cannot imagine a potentially more compromised approach to ensuring competent, qualified home dialysis care,” Dave Walz, MBA, BSN, RN, CNN, FACHE, president of ANNA, said in a press release. “ANNA works tirelessly in the support of advocating only sound educational programs that are optimized to develop, maintain and deliver high-quality kidney care.

“We actively support a cross-disciplinary team approach to patient care and wellness and, while we support interdisciplinary collaboration in delivering high-quality, cost-effective kidney care, we are deeply concerned with the recommendations reflected in the position paper in question,” Walz said.

Members of Innovate Kidney Care (IKC), which released the paper on March 3, include dialysis machine manufacturers, health plans, the National Kidney Foundation and the American Society of Nephrology. The paper is directed at making changes on how home dialysis training is conducted under the Conditions for Coverage, a set of federal rules dialysis providers must follow to receive Medicare reimbursement for patient care.

CMS last revised the regulations in 2008.

Manufacturers’ role

The IKC position paper recommends that CMS “remove the requirement that RNs ‘conduct’ the (home) training, replacing it with ‘having more oversight and participation by a[n]’ RN who can then determine readiness.” Also, the paper proposes manufacturers be allowed to provide patient education.

“CMS should permit home dialysis device manufacturers to directly train patients, under the oversight of the dialysis facility nurse,” the authors wrote. “As more new machines come to market, it is imperative that manufacturers be able to train patients on how to use such machines.”

ANNA, which has more than 8,000 members, said it “strongly disagrees” with the idea of allowing industry personnel to educate patients on home dialysis, saying “the call for an emerging reliance upon home dialysis device manufacturers to directly train patients, under the oversight of a dialysis facility nurse, presents a framework for a compromised dialysis modality experience.

“In addition, the recommendations in the position paper would move toward eliminating qualified nephrology registered nursing oversight that is essential to successful home dialysis therapies and patient safety,” according to the release.

Tonya Saffer

In a response to the statement released by ANNA, Tonya Saffer, vice president of government affairs and market access for Outset Medical and an author of the IKC position paper, said it “put a spotlight on the exponential innovation that has revolutionized treatment options for dialysis patients over the last decade. What hasn’t changed is the need for skilled, trained practitioners to bring innovation and quality care to the patients who need it most.

“Nephrology nurses, nephrologists and skilled providers are a critical part of the patient support team; we fully support their roles in the clinics and at home.”

Nursing shortage

The changes proposed in the IKC position paper are reaction to a “rapidly increasing” shortage of nurses, the authors wrote.

“The outlook for nephrology nurses is especially troubling. ... High turnover is problematic because competent nephrology nurses require between (3) and (9) months of additional experience,” the authors wrote. “In addition, existing regulations require that nurses conduct home dialysis training, leading to the interpretation that the nurse must deliver all aspects of training, despite other care team members having applicable skills and training.

“This situation places an additional burden on nurses, making the shortage an additional challenge for expanding home dialysis.”

However, ANNA said reducing the role of nursing for patient training sets a “dangerous” precedent.

“Of particular concern to ANNA is the recommendation to ‘remove the requirement that RNs conduct training’ and maintain a structured ‘oversight and participation’ in the practice of home dialysis. This is a dangerous and alarming alternative to the existing home dialysis management and presents a threat to patient safety.

“A sustainable home dialysis process starts with education and training by a qualified nephrology-registered nurse,” ANNA said in the release. “Involving the nephrology-registered nurse at the beginning of the process leads to development of a professional patient relationship that fosters trust, familiarity and communication. This is an important step in identifying learning needs and managing patient therapy challenges.

“Early identification of challenges and learning needs is imperative to long-term therapy success.”

Miriam Godwin, public policy director for the NKF and an author of the IKC paper, told Healio Nephrology that the nursing shortage is the main impetus for the proposed changes.

“Our community continues to have a practical problem,” wrote Godwin. “There are simply not enough nephrology nurses to grow home dialysis, especially not now when the pandemic has created severe workforce shortages in some parts of the country.

“Patient safety is of the utmost concern to all of us. We owe it to patients to preserve their safety, provide care that aligns with their values and preferences, and act creatively to find novel and more meaningful ways of providing that care. We can achieve all three at once while acknowledging the practical realities that constrain us.

“We very much hope to work with ANNA to pursue a path forward that meets all of patients’ needs and desires.”