ASN, RPA: Nephrologists may leave Kidney Care Choices model if CMS issues payment cuts
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Key takeaways:
- Reductions in payment to practices participating in the Kidney Care Choices model are based on lower enrollment during the pandemic.
- The payment cuts could lead to practices leaving the demonstration.
Nephrology practices could leave the Kidney Care Choices model for patients with chronic kidney disease because of planned reductions in Medicare payments that are “much larger than anticipated,” according to a nephrology advocacy group.
The Renal Physicians Association joined with the American Society of Nephrology in asking Congressional leadership to intervene on pending reductions in Medicare payment to nephrology practices participating in the Comprehensive Kidney Care Contracting (CKCC) option of the Kidney Care Choices model, which offers capitated payments to nephrologists to manage patients with CKD stages 4 to 5.
The Medicare payment changes, called the retroactive trend adjustment, are based on lower utilization of dialysis services during the COVID-19 pandemic.
“While nephrologists were comfortably aware of the use of the retroactive trend adjustment when entering into CKCC contracts, surprise arose over the magnitude of the reductions,” Keith A. Bellovich, DO, RPA president, told Healio. “These assumptions, using data from years when COVID skewed kidney care utilization, were completely unexpected and two to three times larger than anticipated.”
In the Contracting model, nephrology practices agree to take on a higher financial risk when providing patient care, with the hope that shared savings with Medicare after producing better patient outcomes will recoup that investment.
“These retroactive adjustments would massively reduce if not eliminate any shared savings that nephrologists thought they were signing up for and are impacted by lower care utilization rates observed when the COVID-19 pandemic was at its highest concern for people with kidney diseases,” Bellovich and Deidra C. Crews, MD, ScM, FASN, ASN president, wrote in a letter to Xavier Becerra, HHS secretary, Chiquita Brooks-LaSure, CMS administrator, and Elizabeth Fowler, PhD, JD, deputy administrator and director of the Center for Medicare and Medicaid Innovation (CMMI).
The physician groups urged the Medicare officials to “narrow the risk corridors within the model or consider other proposals to ensure continued participation in CKCC.
“We are concerned that nephrology practices, once aware of this change, will withdraw from participation in the model (and will likely be disinclined to participate in future models),” Crews and Bellovich wrote. “We have heard from practices that they intend to drop out of the model in advance of the financial accountability deadline on April 30 absent changes.”
In a letter to Congress, Bellovich and Crews said nephrology practices are unsure if they will be able to recoup money already spent on office staff to participate in the CKCC demonstration because of the loss in shared savings.
“The retrospective trend adjustment provides no predictability or stability to nephrologists,” they wrote. “These nephrology practices cannot viably operate their businesses knowing that a year after the services are provided, Medicare is going to make such a significant adjustment (ie, move the goal posts). It discourages further investments by nephrology groups to improve care to these patients, which was the goal of the model,” they wrote.
“CMS acknowledged the flaws in making retroactive changes and adjusted their approach for the kidney model starting with performance year 2024 to improve model predictability. Unfortunately, they are not correcting the impact on 2022 and 2023,” Bellovich and Crews wrote. “This leaves nephrologists with difficult choices to make up for the funding loss. They have been forced to reduce staff that provide support to patients, which will hurt their ability to improve care.”
One option to help lessen the burden of the planned cuts is to increase payments for practices when patients remain off dialysis, Bellovich told Healio. “Use of incentives like a positive payment adjustment for practices that succeed in helping persons with CKD delay their disease progression to [end-stage renal disease] is exponentially beneficial and a win-win-win in terms of improved patient care, increased viability of the practices to continue in the models and reductions in expense for the Medicare Trust Fund,” Bellovich said. “RPA is fully aware of the complexities of administering programs like the kidney payment models, but we continue to urge CMS and CMMI to maintain good faith in partnership with nephrologists to find ways to encourage practices to continue their participation in these models.”
References:
ASN/RPA letter to Congress. https://cdn.ymaws.com/www.renalmd.org/resource/resmgr/2024/congressional_comms/24.3.29_asn-rpa_rta_letter_t.pdf. Published March 29, 2024. Accessed April 4, 2024.
ASN/RPA letter to HHS, CMS, CMMI. https://cdn.ymaws.com/www.renalmd.org/resource/resmgr/2024/comm_fed_agencies/24.3.29_asn-rpa_rta_letter_t.pdf. Published March 29, 2024. Accessed April 4, 2024.
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