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The American Association Of Kidney Patients At The Center For Medicaid And Medicare Bundled Prospective Payment System Town Hall Meeting

December 12, 2019

The American Association of Kidney Patients (AAKP) took part in the Centers for Medicare and Medicaid Services town hall meeting for the proposed bundled prospective payment system (PPS). Currently, Medicare pays dialysis services under a partial bundled rate which represent about 60 percent of total Medicare payments to end-stage renal disease (ESRD) facilities. The remaining 40 percent is made of separately billed items for dialysis services such as drugs, laboratory services, supplies and blood products. In 2006, Medicare paid $8.1 billion dollars for dialysis services and related drugs for 315,000 dialysis patients. CMS, through the Medicare Improvement for Patients and Providers Act (MIPPA), has been charged with creating a more efficient payment system that saves Medicare money and provides quality care to patients.

AAKP spoke of supporting the effort to shift Medicare payment systems to increasingly focus on high-value care. But, the Association is concerned that without thoughtful implementation and appropriate oversight, these changes may increase barriers to care for individuals with kidney disease. AAKP Board Member Paul T. Conway, former peritoneal dialysis (PD) patient/current kidney transplant recipient, spoke on behalf of the Association. "A patient who medically requires more previously unbundled biologicals, drugs and/or diagnostic studies may not be accepted for treatment in facilities trying to maximize their margin. Any system that links financial incentives or financial disincentives with limiting access to health care for certain types of patients is easily abused by cherry picking and requires meticulous validation of self reported performance measures."

Conway also expressed the Association's concern that patients have access to the best possible care. "ESRD health care has changed significantly since the initiation of the Medicare ESRD Program. We have witnessed many treatment modality and medication advances in ESRD care. It is essential that all patients have equal access to the best treatment available. AAKP urges CMS to initiate appropriate controls to guarantee these issues are addressed and minimized to ensure equal patient access to high-quality care."

The Medicare Payment Advisory Commission (MedPAC) and the Government Accountability Office (GAO) have both recommended a fully bundled PPS for ESRD services - which include drugs, clinical laboratory tests and other items, and payments could be adjusted to reflect differences in the types of patients treated to ensure that payment to facilities would appropriately reflect the costs associated with treatment.

American Association of Kidney Patients