CMS proposes 2.2% increase in payment rate, offers home dialysis for patients with AKI
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Key takeaways:
- CMS has released a proposed rule that would increase the Medicare bundled payment rate by 2.2% for 2025.
- The agency is also proposing to give patients with AKI the option to do home dialysis.
CMS has released a proposed rule that would increase the bundled payment rate for dialysis treatments by 2.2% in 2025 and allow dialysis providers for the first time to offer home dialysis to patients treated for AKI.
“We believe that the choice of a home modality would be comparable in the beneficiary population for those with AKI as those initiating chronic maintenance dialysis for [end-stage renal disease] ESRD,” CMS wrote in the proposed rule published in the Federal Register. “However, we affirm payment would be provided for either modality of home dialysis.”
The agency wrote that it “believes it is necessary to provide for more flexibility in the modality options available to beneficiaries with AKI” and the expanded coverage would help in “empowering these patients to make decisions about their care.
“Additionally, this proposed change reflects efforts to increase home dialysis access and uptake,” the agency said in a press release, and that the proposed changes “would also support more frequent dialysis at a lower ultrafiltration rate, which may support recovery of kidney function with AKI.”
CMS is proposing to update the payment rate for providing home dialysis to patients with AKI to $273.20, which is equal to the in-center dialysis base rate.
For dialysis providers, the 2.2% increase would result in a new payment of $273.20 per treatment — $2.18 more than the current calendar year 2024 base rate of $271.02.
Last year, CMS provided a 2.1% increase after dialysis providers told the agency that the proposed 1.6% increase in the bundled payment rate was too low.
Oral drugs
The ESRD Prospective Payment System (PPS) has provided a bundled, per-treatment payment to dialysis facilities since 2011 that includes all renal dialysis services furnished for outpatient maintenance dialysis, including drugs and biological products. Placement of oral drugs in the bundle is also included in the proposed rule for 2025, although the kidney community has been asking Congress for help delay the measure.
When the bundled payment rate was first implemented in 2011, CMS excluded oral-only drugs until Jan. 1, 2014, “because we lacked pricing and utilization data for those drugs,” CMS wrote in the press release. “Subsequently, several laws required that payment for oral-only renal dialysis drugs could not be made under the ESRD PPS bundled payment prior to certain dates, ultimately until January 1, 2025.”
CMS added, “In this proposed rule, we are providing information about how we will operationalize the inclusion of oral-only drugs and biological products into the ESRD PPS, as well as budgetary estimates of the effects of this inclusion for public awareness.
“We expect that incorporation of oral-only drugs and biological products into the ESRD PPS will increase access to these drugs, as we have seen previously that incorporating Medicare Part D drugs into the ESRD PPS has had a significant positive effect on expanding access to such drugs for beneficiaries who do not have Medicare Part D coverage, with significant positive health equity impacts,” CMS wrote in the release.
Quality Incentive Program
CMS is proposing to make some changes to the ESRD Quality Incentive Program (QIP) for 2025.
CMS uses the QIP to assess the performance of dialysis facilities based on quality measures specified for a payment year. Providers can get penalized with a payment reduction if clinics do not meet a minimum total performance score.
According to the proposed rule, CMS would replace the Kt/V dialysis adequacy comprehensive clinical measure in 2027 with a Kt/V dialysis adequacy measure topic, which would be comprised of four individual Kt/V measures and scored based on a separate set of performance standards for each of those measures.
“Under this proposed update, the individual Kt/V measures would be adult hemodialysis (HD) Kt/V, adult peritoneal dialysis (PD) Kt/V, pediatric HD Kt/V, and pediatric PD Kt/V,” CMS wrote in the release. “By replacing the current Kt/V dialysis adequacy comprehensive clinical measure with four separate measures, CMS would be able to assess Kt/V performance more accurately based on whether the patient is an adult or child and what type of dialysis the patient is receiving.”
CMS is also proposing to remove the National Healthcare Safety Network dialysis event reporting measure from the ESRD QIP measure set beginning in 2027. Removing the measure “is consistent with evolving the program to focus on a measure set of high-value, impactful measures that have been developed to drive care improvements for a broader set of ESRD patients.
“Although removing this measure would enable facilities to focus on the remaining measures in the ESRD QIP measure set, CMS notes that facilities would still be required to fully comply with the NHSN dialysis event protocol and report all dialysis event data for the NHSN bloodstream infection clinical measure,” CMS wrote.
If finalized, Medicare expects to pay $7.2 billion to approximately 7,700 facilities for furnishing renal dialysis services under the proposed rule, which can be downloaded from the Federal Register at https://www.federalregister.gov/d/2024-14359.
Comments on the proposed rule are being accepted through Aug. 26.
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