Transplant society asks CMS to delay launch of new payment model
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Key takeaways:
- The American Society of Transplantation is asking CMS to delay the start of a new payment model aimed at increasing kidney transplants.
- The demonstration would start in January 2025 and last 6 years.
The American Society of Transplantation has asked CMS to delay up to a year the launch of a 6-year demonstration aimed at increasing kidney transplants and improvements in graft survival.
“ … [American Society of Transplantation] AST recommends that the [Increasing Organ Transplant Access] IOTA not be implemented as proposed based on concerns about operational challenges, adverse financial impacts and potential disruptions to transplant patient care that may result from IOTA,” Jon Kobashigawa, MD, AST president, wrote in submitted comments to CMS on the proposed rule.
CMS received 160 comments on the proposal, which was released in May. In a fact sheet, the agency wrote that the payment model “would focus on encouraging transplant hospitals to use more of the kidneys that become available for transplantation and facilitate more transplants from living donors.” The model is also designed “to support greater care coordination, improved patient-centeredness in the process of being waitlisted for and receiving a kidney transplant and more equitable access to kidney transplants,” the agency wrote. “Through the model payments and policies, CMS aims to increase the care delivery capabilities and efficiency of kidney transplant hospitals selected for participation, with the goal of improving quality of care while reducing unnecessary spending.”
Based on the proposed rule, approximately 90 transplant centers would participate in the model. Eligible hospitals would be non-pediatric transplant hospitals with an active kidney transplant program that perform an annual average of 11 or more kidney transplants in the 3 baseline years before the start of the model in 2025.
IOTA model
In the letter, Kobashigawa wrote that AST had numerous concerns about the model including how the transplant centers are being selected for participation, the 6-year timeline, how baseline and performance metrics are determined and the amount of the financial incentives being offered for centers that improve transplant rates. Kobashigawa also wrote that transplant centers needed more time to prepare for the January 2025 start date.
“AST is concerned that the rapid initiation and short runway for IOTA may present significant challenges for transplant programs in securing the necessary resources to meet program criteria,” Kobashigawa wrote. “AST proposes that CMS delay implementation of the model by 6 to 12 months to enable transplant hospitals to budget for, and to put in place the prerequisite infrastructure that will be needed for the model to derive its intended benefits.”
Kobashigawa wrote that the 6-year duration of the model “is concerning due to uncertainties around potential changes to CMS reimbursement for organ acquisition costs and other concurrent changes affecting the field. Instead, AST proposes that a more feasible model would be a 12- to 18-month pilot initiation project starting Jan. 1, 2025 (or later as proposed above), with CMS working with selected programs to align scores with improvement efforts, assess resource needs, and develop workflows, tracking and reporting mechanisms.”
Discard rate
One of the goals of the payment model is to reduce the rate of organ discards — kidneys that are procured but deemed unsuitable by surgeons at transplant centers. Data from the Association for Organ Procurement Organizations show that 19% of organs procured were discarded by transplant centers in 2022 because the organs were deemed unsuitable for transplant. But Kobashigawa defended the need for organ selection, writing in the letter, “AST encourages CMS to consider that placement of higher-risk organs [for transplant] requires greater effort and more manpower that is not reflected in reimbursement under IOTA or other payment models,” he wrote. “This concern is heightened by changes that CMS is considering to the organ acquisition cost policy. If implemented, changes to that policy would have a substantial impact on reimbursement that could be exacerbated by the IOTA payment model.
“Further, other recent changes have dramatically increased the costs of transplantation without commensurate increases in reimbursement,” Kobashigawa wrote. “Therefore, AST fears that the IOTA proposal would compound that financial strain on transplant centers and transplant physicians.”
Payment structure
The model would build on previous efforts by CMS in developing performance-based models that offer financial incentives, such as the ESRD Treatment Choices model, launched in 2021, and the Kidney Care Choices model, launched in 2022.
“A participating transplant hospital would receive upside risk payments from CMS, fall in a neutral zone in which the hospital neither receives an upside risk payment nor owes a downside risk payment, or owe downside risk payments to CMS, based on the participating transplant hospital’s final performance score,” according to the CMS fact sheet.
The final performance score would be calculated up to 100 points based on a set of proposed metrics. These include the following:
- achievement based on the number of kidney transplants (60 points);
- efficiency based on the organ offer acceptance rate ratio (20 points); and
- quality based on the CollaboRATE Shared Decision-Making Score, colorectal cancer screening, three-item care transition measure and a post-transplant composite graft survival rate (20 points).
To see a copy of the proposed rule, click here.
Reference:
https://www.healio.com/news/nephrology/20230808/high-rate-of-donated-organs-going-unused-is-costing-lives. Published Aug. 6, 2023. Accessed Sept. 13, 2024.
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