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November 19, 2009


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roberta mikles

Peter, thank you for posting this area of which demands attention and inclusion in all public comments.
Roberta Mikles, RN
Patient Advocate

Lori S.

I agree completely with your view. This past week I submitted my comments to CMS on the proposed bundle and asked that they take a step back and reimburse all patients at the same rate, and also to reconsider adding any additional labs or meds. They have cost and reimbursement information to determine a fair rate on these items, but when they start adding Part D meds and additional labs the amounts they are considering for reimbursement are too low in my population. It is also difficult to explain to patients why one has a higher rate per treatment than another patient - sometimes by as much as $100, and why the rate changes monthly. We all have a variety of patients to treat, and the difference will come out in the wash. Another administrative cost I am not looking forward to is collecting copays, not just on treatments, but labs and meds. The bundling should simplify claims and the claims process, not make it more difficult.

Roberta Mikles

Is inclusion of Part D drugs not somewhat discriminating? It now seems with the inclusion of Part D drugs that those individuals with ESRD will have their Part D implemented different. This was NOT the intention when Part D was first initiated. Just seems so discriminatory
Roberta Mikles

roberta mikles

Clarification as I received a private email re post-----..

Medicare Part D is available to non-ESRD beneficiaries and ESRD beneficiaries now. However, in the proposed rule, with inclusion of Part D drugs, it seems that those with ESRD will NOT have the same Part D benefit as those non-ESRD beneficiaries, therefore, is this not somewhat discriminatory?
Roberta Mikles

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