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    « CMS releases final dialysis payment rule | Main | The Dialysis Quality Incentive Program rule proposed - CMS calls for comments »

    July 26, 2010

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    Nancy Murrell

    Bundling worries me a little bit, in that dialysis appointments are the most frequent medical treatment opportunity for kidney patients. Flat rates might discourage additional needed treatment that might otherwise happen at these appointments. I also wonder how bundling may affect innovation in equipment and IV medications for kidney disorders. At the same time, we need to contain costs and maximize the amount of treatment we can give to the most people.

    What do you think?

    Dori Schatell

    CMS claims it's going to study virtually every aspect of how care is affected by this new bundle. In theory, that sounds nice. In practice, they're going to need a lot of guidance to look in the right places, and not just at the "usual suspects." As far as seeing nephs, for example, my reaction was that a lot more time is going to be taken up checking off tick marks for what other illnesses folks had in the past or have now, to get more $$, and a lot less time spent on...whatever it was spent on before at those visits. How do you measure whether you are still seeing an MD, but now your needs are not met? Satisfaction, I suppose, but there's no good tool to measure that, nor does it predict ANY other outcome measure.

    Zach

    Now is the time to consider and comment on the proposed rules for the End-Stage Renal Disease Quality Incentive Program (QIP).

    http://www.ofr.gov/OFRUpload/OFRData/2010-18465_PI.pdf

    Comments must be received no later than 5 p.m. eastern standard time (EST) on September 24, 2010.

    Dori Schatell

    Congress, I think, did not give a lot of thought about what "bundling" services under Medicare Part B was going to mean as far as higher co-pays. When the "composite rate" was about $150/treatment, the 20% co-pay was about $30 treatment x 12 standard HD treatments per month = $360.

    With the base rate for dialysis at about $250--with MANY people's treatments costing more than that, say, $300, the co-pay doubles to $720/mo. During the first 120 days there's a 51% add-on. Good for clinics: now they're making, say, $400 per treatment. Not so good for dialyzors, who'll be responsible for $80/treatment--or $1,000 co-pay per month for those first 4 months.

    It will almost certainly be cheaper to get SOME kind of backup healthcare plan than to pay those co-pays out of pocket. Non-payment IS a reason that clinics can drop folks. Some options: Medigap in states that allow it, an employer group health plan, a state plan (check http://www.healthcare.gov.)

    Bill Peckham

    Your copays are about the same if you are an "average" patient - since you would have been paying the 20% on the separately billable items too. If you use more than average EPO, Iron, etc then your copays could be less.

    The copays for labs are new, to the extent that they're in the new bundle but they aren't that much.

    The big one is the first 120 day adjuster but if it is used no other patient level adjustments apply. CMS addresses concerns about copays in their final rule - when it comes to the Part D drugs, having them covered under Part B will represent a savings for a lot of people.

    I"d say the copay issue is a mixed bag.

    Dori Schatell

    You weren't previously paying co-pays on lab tests, which are now included in the bundle, and having drugs in the bundle also eliminates Part D help, which a lot of dialyzors were eligible for. I still think folks are going to come out behind.

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