All NKF Regulatory Comments
Table of Contents
Funding for Innovation, Prevention, and Research
- Letter to Senate Health, Education, Labor, and Pensions (HELP) Committee on addressing healthcare workforce shortages (March 2023)
- Letter to the Food and Drug Administration (FDA) on the prioritization of innovative research and increased investment in therapeutics for immunocompromised kidney patients (February 2023)
- Letter to state Medicaid directors on ensuring undocumented patients have access to dialysis care (September 2021)
- Letter to the Centers for Medicare and Medicaid Servies (CMS) on the challenges in and opportunities to improve kidney care nationwide (September 2021)
- Letter to the Centers for Disease Control and Prevention (CDC) on the need to issue additional guidance specifically directed toward immunocompromised patients regarding the need for continued masking and social distancing, even after receiving a COVID-19 vaccine (May 2021)
CKD Awareness and Detection
- NCQA BP Letter
- Letter to the American Board of Internal Medicine (ABIM) Nephrology Board on current and emerging competency standards for nephrology fellow procedure requirements (May 2023)
- Coalition for Kidney Health (C4KH) letter to CMS on the Medicare Advantage (MA) Advance Notice (March 2023)
- C4KH letter to the United States Preventive Services Task Force (USPSTF) on their a draft research plan to assess screening, interventions, outcomes, and disparities in chronic kidney disease (CKD) (February 2023)
- Letter to OPTN on the need to promote transparency in the transplantation process and improve equitable access (September 2022)
- Letter to CMS in response to a Request for Information (RFI) on MA plans and their potential to significantly improve the lives of individuals with CKD (August 2022)
- Letter to CMS on the increasing relevance of MA plans to CKD patients (March 2022)
- Joint letter with ASN, the American Nephrology Nurses Association (ANNA), and the Renal Healthcare Association (RHA) to administration leadership on the need to prioritize the unique needs of kidney patients in the response to the Omicron variant of SARS-CoV-2 (January 2022)
- Letter to the Health Resources and Services Administration (HRSA) about early detection of CKD in Federally Qualified Health Centers (FQHCs) (January 2021)
- Letter to CDC on the special vulnerability of kidney patients to COVID-19 (January 2021)
- Letter to CMS on the proposed Payment Policies under the Physician Fee Schedule (PFS) for Calendar Year (CY) 2022 (September 2021)
- Letter to CDC encouraging additional guidance specifically directed toward immunocompromised patients after receiving a COVID-19 vaccine (May 2021)
Access and Affordability
- Letter to House Ways and Means Committee on improving access to health care in rural and underserved areas (October 2023)
- Letter to administration leadership in the Department of Health and Human Services (HHS) providing comments on the Medicare Program; End-Stage Renal Disease (ESRD) Prospective Payment System (PPS), Payment for Renal Dialysis Services Furnished to Individuals with Acute Kidney Injury (AKI), ESRD Quality Incentive Program (QIP), and ESRD Treatment Choices Model (August 2023)
- Letter to administration HHS leadership on ensuring access to Medicaid services for CKD patients (July 2023)
- Letter to CMS on the proposed Fiscal Year (FY) 2024 Hospital Inpatient Prospective Payment System (IPPS) rule (June 2023)
- Letter to strongly encourage the FDA and other biotechnology stakeholders to increase investments in innovative research and expedited access to therapeutics to protect kidney patients against COVID-19 (February 2023)
- Letter to CMS on improving patient care, reducing health disparities, and promoting health equity as top priorities in alignment with both the CMS Framework for Health Equity and the Advancing American Kidney Health initiative (AAKHI) (February 2023)
- Letter to CMS urging considerations to ensure every kidney failure patient has fair access to home dialysis and kidney transplantation (February 2023)
- Letter to CMS commending its implementation of the Comprehensive Drug Coverage for Kidney Transplants Act of 2020 (October 2022)
- Letter to OPTN offering commentary on its policy proposal to modify wait time for candidates affected by race-inclusive eGFR calculations (September 2022)
- Letter to CMS commenting on the CY2023 Payment Policies under the PFS (September 2022)
- Letter to CMS on proposed revisions to Payment Policies under the PFS for CY2021
- Letter to CMS on the proposed CY2023 ESRD rule and the importance of improving the patient experience of kidney disease (August 2022)
- Letter to HRSA commenting on its RFI regarding the OPTN and the importance of increasing accountability, enhancing the usability of its system and tools, and strengthening access in its processes (May 2022)
- Letter to CMS commenting on the MA Advance Notice and the importance of maximizing its benefits to kidney patients (March 2022)
- Written testimony to the National Academies of Science, Engineering, and Medicine (NASEM) on behalf of NKF CEO Kevin Longino advocating for a fairer and more equitable transplant system (August 2021)
- Letter to CMS commenting on the proposed FY2022 inpatient rule (June 2021)
- Letter to the Membership Professional Standards Committee (MPSC) of the OPTN regarding its transplant performance measure proposal (May 2021)
- Letter to the Executive Committee of the OPTN commenting on its 2021-2024 Strategic Plan (March 2021)
Equity
- Advancing Equity in Kidney Health position paper (September 2023)
- Joint letter with ASN thanking the Agency for Healthcare Research and Quality (AHRQ) for its commitment to eliminating racial and ethnic disparities in health and healthcare (March 2023)
- Joint letter with ASN to HRSA on expanding the organ supply and transplant access by removing race from the Kidney Donor Risk Index (KDRI) and Kidney Donor Profile Index (March 2023)
- Joint letter with the American Society of Nephrology (ASN) to the Organ Procurement and Transplant Network (OPTN) on their policy to modify wait time for Black transplant candidates affected by the race-based estimated glomerular filtration rate (eGFR) calculation (February 2023)
- Letter to OPTN commenting on its white paper, Ethical Evaluation of Multiple Listing, and highlighting its potential to advance equity in transplantation (March 2023)
- Letter urging OPTN to ensure living organ donors are prioritized for transplant in the event they require a transplant (March 2023)
- Joint letter with ASN asking CGS Administrators, LLC, to align its medical policies to better assess kidney function (April 2022)
- Letter to OPTN supporting its proposal to remove race from the algorithms used to assess kidney function (March 2022)
- Letter to CMS commenting on the CY2022 ESRD PPS and QIP (August 2021)
Kidney Failure
- PFS Letter
- Letter to OPTN on its policy proposal to require reporting of patient safety events (September 2023)
- Letter to OPTN on its concept paper for a collaborative approach to living donor data collection (September 2023)
- Letter responding to CMS RFI on the hospital benefit and its intersection with the Medicare ESRD benefit (May 2023)
Transplantation
- Re: OPTN Board Contract Extension
- OPTN Special Comment Period: Expedited Placement Variance
- Letter to OPTN applauding steps to improve transplant outcomes for kidney recipients (September 2023)
- Letter to OPTN on the importance of removing administrative barriers that could delay highly sensitized patients from receiving a kidney transplant (September 2023)
- Letter to OPTN on optimizing usage of organ offer filters (March 2023)
- Letter to OPTN on its policy proposal to update kidney paired donation policy (September 2022)
- Letter to OPTN cautioning against making kidney offer filters mandatory (September 2022)
- Letter to CMS commenting on the CY 2023 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center Payment System (ASC)
- Letter to OPTN on its policy proposal to establish minimum donor criteria to require biopsy (March 2022)