By Bill Peckham
No new PPS comments were posted today (you can view the comments here or download the continuously updated Excel file), but I am expecting at least a few more. I haven't seen one from KCC or from FMC, I expect they'll be posted early next week.
So far I have 1,115 comment on my PPS spreadsheet. They run the gamut from the actionable to those that can be summarily dismissed. I'll have a more in depth analysis once I think all the comments are posted. There were a lot of great comments from dialyzors. Dialyzors using the NxStage are vastly over represented. I can't wait to count up the comments from people using the NxStage (and NxStage family members). I think home dialyzors really came through to improve this rule for everyone. If CMS really listens to their beneficiaries they'll get rid of medical justification and pay fairly for home training.
I'll compile and post from the best dialyzor comments soon, until then here is my favorite comment out of all that were submitted, in the non-dialyzor category.
It's the 1,112th comment I read. Maybe I'm just loopy from all the previous multipage entries, but I thought this one broke through in an engaging way, to tell a story that made the author's point, in fewer than 2,000 characters. (The submission was through the website interface so it was limited to 2,000 characters (the web interface also strips paragraph breaks, I've made a guess where to add them to improve the comment's readability.)):
I will never forget the first time a dialysis patient was upset with me. It was 15 years ago. I was an undergraduate Dietetic Student at the University of Vermont. I was interviewing dialysis pts on their calcium/phosphorus intake. One Saturday morning 2 pts absolutely refused to participate.
I had interviewed each of them 15 times before, but today, interviews were not going to happen. Why? The pts refused, saying; "we're trapped here in a chair. we're prisoners. We're going to sit here for 4-5 hours on a Saturday, and then spend most of our weekend trying to recover. You're going to ask a bunch of questions and then run off to enjoy your day. We don't want to help you".
What they were really saying is that they wanted to be free. They wanted to recover faster and feel better. They wanted a more "normal life". Why do i remember these 2 pts? Having now worked with many home hemodialysis pts, I know that these 2 pts should NOT have been in that center, not these 2.
They should have been treating at home, they should have been enjoying the benefits of daily home hemodialysis. Clinical evidence tells us that pts performing more frequent, home hemodialysis, realize faster recovery times post-treatment, a reduction in BP meds, increased levels of energy, less depressive symptoms, improved mental and physical capabilities, etc...
I applaud CMS for including in the proposed rule a stated goal of encouraging more home dialysis, and for allowing providers the opportunity to bill for more frequent therapy, which has been proven to improve the lives of patients. Unfortunately, because the stated rule fails to appropriately capture the costs associated with providing the essential HHD training required for home patients, I fear you are working against your stated goal.
Please reconsider the elimination of separate payments for home hemodialysis training. You are so close to hitting the mark, improving cost of care and quality of life. Help keep pts home and free.
That's a great comment. If you're the renal dietitian from CA congratulations, you won the best comment nonDialyzor award.
In your honor I went through and corrected the spelling of "Dietitian" in Column P across all 19 page of the spreadsheet.
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