NKF Comments to Medicare on ESRD Payment System

People whose kidneys have stopped working need dialysis, a treatment that cleans their blood since their kidneys can't do it anymore. Medicare pays dialysis clinics a set amount of money for each patient's care. This payment system is called the ESRD PPS (End-Stage Renal Disease Prospective Payment System). Every year, CMS updates the rule to decide how much clinics get paid and what good care should look like.

NKF shared its thoughts with the Oz administration on several parts of the new rule, focusing on making sure people with kidney failure get the care they need.

The Basic Payment Amount

• CMS proposed a new base payment amount for each dialysis treatment. 
• NKF thinks this amount is fair for most clinics. But they asked CMS to keep a close eye on clinics that treat harder cases — like patients in rural areas, children, and people who dialyze at home. These clinics often have higher costs, so NKF wants to make sure they're not left behind.

Protecting Patients With Complex Needs

• Sometimes a patient needs extra, unusually expensive care. Medicare has a backup payment for these cases so clinics don't lose money treating sicker patients. CMS wants to raise the amount a clinic must spend before this backup kicks in, and raise it by a lot. 
• NKF is worried this big jump could make it harder for clinics to get that extra help when patients truly need it.

Paying for New Medicines

• NKF weighed in on medicines called phosphate binders, which help control a mineral called phosphate in the blood. 
• CMS wants to fold the cost of these medicines into the regular payment.
• NKF supports this idea but wants CMS to make sure clinics can still afford to deliver, explain, and support patients in taking these medicines, and to raise the payment if it turns out not to be enough.

Helping Small and Rural Clinics

• Small clinics that treat fewer patients often cost more to run per patient.
•  CMS has a special payment boost for these clinics called the Low-Volume Payment Adjustment.
• The new rule would give the smallest clinics the biggest boost. NKF supports this change.

Protecting Care for Children

• Kids on dialysis have different needs than adults, and it often costs more to treat them. 
• Right now, there's a temporary payment add-on for pediatric care.
• NKF wants CMS to make this permanent instead of temporary and make sure the payment reflects the special costs of caring for children. 

Making Home Dialysis Easier

• Some patients do dialysis at home instead of going to a clinic. 
• Learning how to do this takes training, and NKF strongly supports a solid raise in the payment for that training. 
• We also want clinics to be allowed to start this training right when a patient begins dialysis, not just later. 

Measuring Quality of Care

• Medicare also tracks how well clinics are doing through a scorecard system called the ESRD Quality Incentive Program (QIP). NKF suggested two changes:
  • Instead of tracking high calcium levels, NKF supports tracking high phosphate levels instead, as long as CMS carefully checks how this affects different patients and doesn't create unfair results.
  • NKF supports a new measure where clinics regularly talk with patients about their personal life goals, paired with checking in on symptoms, daily function, recovery time after treatment, and overall quality of life.

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Overall, NKF's message to CMS is this: the proposed payment update is a solid step forward, but Medicare needs to pay closer attention to the patients who are hardest to serve- children, rural patients, home dialysis patients, and people with complex medical needs- to make sure the payment system actually works for everyone, not just the average case.