By Bill Peckham
There are now over 300 comments to the proposed rule to implement a new prospective payment system for facilities that provide dialysis services to Medicare beneficiaries (PDF link (183 pages)). There have not been very many comments by dialyzors, only about half a dozen commenters have identified themselves as current or former dialyzors. I hope that number will grow.
Yesterday I participated in the first Northwest Kidney Centers forum on the payment bundle. I would have liked it to have been standing room only (there were 17 or so) but I understand that my level of interest is unusual. Having a meeting on the details of Medicare's dialysis reimbursement policy is a tough sell. Really to understand how complicated dialysis reimbursement is try explaining it in ten minutes. I was asked to the effect "Why should I care about this?".
It's a good question. I answered that it matters. The details of the proposed rule matter and I think the rule can be improved. I made the point that Medicare would very much like to hear from their beneficiaries and those who love us. That this is an historic opportunity to improve how dialysis is provided and that we'll be living with the consequences of this rule for many years. Even if you never need dialysis or never need dialysis again, by taking time now to read about and understand this rule you can improve dialysis for the people who will. And I believe you, you who understand, have an obligation.
It'll take some time; it'll take some effort but it's not a long term commitment. You only have until December 16th (Medicare just announced that the deadline has been pushed back a month). If you don't understand how this rule might impact dialysis then go to the Renal Support Network's Kidney Public Policy 101 discussion board and/or the Northwest Kidney Centers Medicare Bundling Proposal page. When you are ready to comment read the NKC guidance Give Input to Medicare and make yourself heard. For all the comments that have been made a lot still needs to be said.




The NKC guidance Give Input to Medicare states: "By mail to arrive before Nov. 16 at ... "
Is that correct or a typo?
Posted by: Zach | November 05, 2009 at 07:36 AM
Good catch Zach. That was the original deadline, I've made the correction to the new deadline - December 16, 2009..
RenalWEB has the announcement of the deadline change posted as a PDF.
Posted by: Bill Peckham | November 05, 2009 at 08:55 AM
It was great to hear about the major components of the proposed rules at the forum...It is a difficult concept and very helpful to talk it out in person. I would encourage everyone to go to one of the forums this weekend - Nov. 7 in Seattle and Nov. 8 in SeaTac. Details on www.nwkidney.org.
Posted by: Francie | November 06, 2009 at 09:52 AM