ESRD PPS Public Comments Available as Excel File or Web Page

By Bill Peckham

So far nearly 300 comments have been made in response to the ESRD Prospective Payment System Proposed Rule. The comment period goes through November 16th. If you are ready to comment submit them here. If you don't understand how this rule might impact dialysis then go to the Renal Support Network's Kidney Public Policy 101 and/or the Northwest Kidney Centers Medicare Bundling Proposal page.

The public comments to Medicare are being collected, characterized and published by DSEN through Google documents in order to understand what is being said and what is being missed:

The above spread sheet is available to view on its own html page, or you can download the file as an Excel file. The comments are in the process of being characterized as speaking to Home Hemo Training; Amount of Payment; Labs; Oral Drugs; QIP; Case Mix Adjustment; Race Adjuster; Method II; Small Volume Facility; IV Meds; Blood Transfusions; CoPays and Identity of Commenter. Categorizing the comments is an going process; as comments are added and characterized the spreadsheet and links will be updated. (Notice that Google documents limits their spreadsheets to about 100 rows, as a result the comments are on three separate sheets of about 100 comments each. In order to sort the comments by what category has been checked you should download the Excel file, combine all sheets into one and then sort).

The majority of the comments express concern about including oral drugs in the bundle and while many commenters do not identify their connection to dialysis it does seem that dialyzors are vastly underrepresented. If you'd like to help characterize the emails or have any feedback drop me an email or comment. Now is the time to get up to speed, Medicare wants your feedback on the proposed change.

Comments

[roberta mikles]

Continues to seem like most comments are focused on inclusion of oral medications. A few refer to home training.

[Bill Peckham]

I just heard that CMS is extending the comment period to December 16, another month. I was just thinking I need more time.

I haven't done a count but there is no doubt Roberta that oral drugs generated the most comments. It's a surprise when they are not mentioned. Hopefully people will take time to check a few more of my columns in their comments.

[Zach]

I too, need more time.

[Roberta Mikles]

I applaude CMS for extending the deadline. This is a most crucial turning point in the lives of dialyzors and should be given every consideration available. I still wish that some legislators would stop and realize that which might negatively affect dialzyors, as well as providers, and might not be in the best interest of dialzyors. Perhaps some legislators could intervene, at some level, and have 1418 (Jan 1, 2011) postponed so until we see how our overall health care reform will affect the lives of dialzyors. There must be a way!!!!!!!!!!!! 1418 might very well be in gross conflict with our new health care reform. Would it not be wise to wait and see?
Roberta Mikles, RN
Advocates4QualitySafecare