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CMS Finalizes Flat Payment and New Quality Measures for Dialysis Facilities

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In the Calendar Year (CY) 2015 End Stage Renal Disease (ESRD) Prospective Payment System (PPS) final rule released on October 31, the Centers for Medicare & Medicaid Services (CMS) finalized a 2015 base per treatment rate of $239.43, up slightly from $239.02 in CY 2014.

The payment update reflects the requirement set forth in the American Taxpayer Relief Act (ATRA) of 2012 and reinforced in the Protecting Access to Medicare Act (PAMA) of 2014 that instructed CMS to adjust the bundled payment to dialysis clinics to reflect recent changes in utilization of ESRD-related drugs and biologicals.

CMS finalized its proposal with modifications to rebase and revise the CY 2015 ESRD market basket so the cost weights and price proxies reflect the mix of goods and services that underlie ESRD bundled operating and capital costs for CY 2012. CMS also finalized technical adjustments that will have a significant impact on payments to providers with very low or high wage indexes.

Additionally, CMS finalized changes to the ESRD Quality Incentive Program (QIP) for payment years (PYs) 2017 and 2018, reflecting dialysis facility performance in 2015 and 2016 respectively.

PY 2017: CMS finalized its proposal to remove 1 clinical measure and add 1 clinical measure.

Dropped measure: Hemoglobin Greater than 12 g/dL clinical measure, as CMS has determined the measure is “topped out.”

New measure: Standardized Readmission Ratio (SRR) clinical measure, aligning the ESRD QIP with other quality reporting programs.

PY 2018: CMS finalized its proposal to add 3 new clinical measures and 3 new reporting measures.

New clinical measures: 1) Standardized Transfusion Ratio (STrR); 2) Pediatric Peritoneal Dialysis Adequacy; and 3) In-Center Hemodialysis Consumer Assessment of Healthcare Providers and Systems (ICH CAHPS), which is currently a reporting measure.

New reporting measures: 1) Pain Assessment and Follow-Up; 2) Clinical Depression Screening and Follow-Up; and 3) National Healthcare Safety Network (NHSN) Healthcare Personnel Influenza Vaccination.

Separately, CMS finalized a methodology for using information from the Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) Competitive Bidding Program (CBP) to adjust the fee schedule amounts for DME, enteral nutrition and off-the shelf orthotics in areas where CBPs are not implemented. CMS also finalized the limited phase-in of a new methodology to pay for certain DME (i.e., CPAP devices and standard power wheelchairs) on a bundled, continuous rental basis.

Medicare payments to dialysis facilities will remain relatively stable in CY 2015. However, providers in areas with low wage indexes will see a decline in payments, while providers in areas with high wage indexes will see an increase in payments.

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