The revised RFA includes major adjustments to the ESCO model based on feedback from dialysis providers and other constituents, including:
- The nephrologist and/or nephrology practice does not need to be an independent entity from the owner dialysis facility.
- The guaranteed discount for large dialysis organization (LDO) ESCOs only applies to non-dialysis FFS Medicare Parts A and B spending.
- CMS is no longer offering two risk track options for non-LDOs, limiting these providers to a one-sided (upside-only) risk track.
- The benchmark will not be rebased in years four and five, although the ESCO contract period remains a three-year agreement with an optional fourth and fifth year.
CMMI initially intended to approve 10-15 ESCO applications for participation in Year 1 of the program, but encountered high levels of reluctance from dialysis organization due to concerns over some of the specific provisions. The revised RFA represents the Agency’s most recent attempt to further stimulate provider participation in the ESCO program, Medicare’s first disease-specific shared savings initiative.
Letters of Intent and completed applications are due on June 23 for LDO applicants and Sept. 15 for non-LDO applicants.