CMS submits dialysis "Bundled" Payment Rule to OMB

By Bill Peckham

UPDATE 7/16/2010:
Here it is a week later than my "best guess", just about 2PM in DC. The rule could come out in the next three hours but if it doesn't then it'll probably come out  (just to spite me) when I am on the river and beyond the reach of the internet. Google has DSEN (this post in particular) pretty high up as a search result relating to people searching for news about CMS's final Dialysis Bundle rule, so if that's how you got here let me give you the links I've been checking for news:

• CMS's End Stage Renal Disease (ESRD) Center
• CMS End Stage Renal Disease (ESRD) Payment - Overview
• CMS End Stage Renal Disease (ESRD) Payment - Spotlight
• CMS End Stage Renal Disease (ESRD) Payment - Payment Regulations & Notices

One of these sites (or all of them) should announce and link to the final rule when it is released. If the rule is released between 7/19 & 7/23 you'll have to wait until I return for the POV from this sharp end of the needle.

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ORIGINAL POST FROM 7/1/2010:
The Centers for Medicare and Medicaid Services (CMS) has submitted the End Stage Renal Disease Bundled Payment System final rule to the Office of Management and Budget (OMB) for final evaluation. This is the final step in a process that began last September.

Typically OMB review takes about a week and often these rules are released to the public on a Friday, therefore, the best guess is that CMS will publish the final PPS rule on Friday July 9th. A caveat is that OMB could request additional data, resulting in the rule ping ponging between the two federal departments for a few days, but the end is in sight. 

There have been rumors and hints of what will be in the final rule. I think the CKD advocacy community is expecting that oral meds will not be in the bundle (which means certain people owe me dinner). Of greater interest to DSEN, and the community of dialyzors that submitted comments, I hear that the final rule will include a separate payment accommodation for home training. If true, a meaningful home training payment mechanism will be the most important element of the new dialysis payment scheme.

Comments

[Peter Laird, MD]

Bill, that would be good news and a testimony to all those that spent hours diligently reading and reviewing the bundle proposal with the myriad of comments sent in to CMS.

[Denise Eilers]

Bill, I certainly hope you are right. Home dialysis offers patients the chance to be in total control of their health and treatments. It only makes sense to encourage patients to fit dialysis into their present lifestyle of work, social life, and family. Otherwise, we continue the mindset of viewing CKD5 patients as sick and disabled. I personally believe that attitude is unconscionable.

[roberta mikles]

Bill, I agree also and hope you are right. Our group's (Advocates4QualitySafePatient Care) comments, as many others, focused on these areas. We have always supported home dialysis. In fact, there are many units now who are really pushing for home dialysis ( after the bundle was made public) with posters on walls, home dialysis material throughout the units, etc. My question is why didn't providers do this prior to the bundle? Well, we know the reason, don't we? Was the patient not important enough to have home dialysis pushed as it is now? The important thing is that providers are now more focused on home. And, of course, meds should not be excluded - providers had a great influence here to exclude - - their influence has outweighed what patients wanted many times BUT this time patients did not want inclusion. We can continue to hope that the OMB will approve. Thank you for continuing to keep us all aware of that which is happening.
Roberta Mikles RN
Patient Safety Advocate
San Diego, CA

[roberta mikles]

CORRECTION ---And, of course, meds should not be INCLUDED..

wow, sorry for that.
Roberta

[Pat]

Can someone please help an uninformed, but interested, outsider on the oral meds question? Is it a good or bad thing that DaVita and Fresenius have their own pharmacy beenefits/specialty mail-order pharmacies? Thanks.

[Bill Peckham]

Pat in general I think it could be to the patients benefit for providers large and small to be in the loop as far oral medications. Like anything whether it is good or bad depends on the details - things like quality measures, payment amounts.

I hope that the PPS required under MIPPA will not include oral drugs but that drugs will be included and fairly reimbursed, once the GAO completes their report; at which time CMS will have implemented the appropriate quality standards and reporting.