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 proposes to make other technical adjustments that will have a significant impact on payments to providers with very low or high wage indexes.

CMS also proposes 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 proposes to remove 1 clinical measure and add 1 clinical measure.

PY 2018: CMS proposes to add 3 new clinical measures and 3 new reporting measures.

As expected, Medicare payments to dialysis facilities are proposed to 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. Other proposed changes could result in significantly lower inflationary updates in future years. The proposed increase of clinical quality measures in the PY 2017 and PY 2018 QIP presents an opportunity for manufacturers to further demonstrate the value of products included in the bundle.

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.

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 proposes a methodology for making national price adjustments to Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) based upon information from the DMEPOS Competitive Bidding Program. The rule also proposes the limited phase-in of a new methodology to pay for certain DME and enteral nutrition on a bundled, continuous rental basis. These proposals address some of the same issues raised by CMS in the Advanced Notice of Public Rule Making published on Feb. 26, 2014.

Public comments are due by September 2, and a final rule is expected in early November.

View CMS’ full ESRD rule.