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January 19, 2010

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Peter Laird, MD

Bill, unfortunately, this legal action combined with the negative ESA studies showing harm at even low levels of EPO use, the likelihood is that we may actually see a lower base rate for the bundle when the final rule comes out. We may be advocating to return to the meager $198. With the practice patterns that are likely to change dramatically, fiscal solvency of dialysis units will likely become the most pressing matter in the next several years. We are already seeing the tip of the iceberg so to speak with Grady Memorial Hospital closing it's doors to indigent dialysis patients. This new legal action only compounds the elements that were already present. Patients will once again be the victim of these dramatic events.

Rich Berkowitz

No wonder ESA's were mandated to be part of the bundle. The greed of for-profit centers has backfired and now all dialyzors may pay the price. On the plus side, DaVita's hiring of Dr. John Moran must be seen as a positive sign. John is one of the leading advocates for home dialysis, especially optimal nocturnal. I will miss him at Wellbound. Could his hiring be somewhat due to DaVita's past practices and John coming in as VP of Clinical Affairs and Home Dialysis be their way of putting in a fix? Let's hope so.

Bill Peckham

I don't think we need loose sleep over the dialysis business model. After all, if you miss the hct targets in the QIP the "fine" will be about 1% (assuming CMS splits the 2% at risk between hct and URR).

Well you can save a lot more than $2.35 in EPO if you are unconcerned about the QIP target. And as I mention in this post $235 is a more accurate representation of the value of the proposed payment.

The PPS process is mandated by MIPPA which mandates that the bundle is to be the value of payments less 2%. I can't see a way for CMS to acknowledge that previous payments include the overuse of EPO. Although I, and commenters such as Dennis Cotter, are very sure it does. This is all to say Peter, that the greater risk is that the PPS represents a potential give away to providers.

Between the latest research and the incentives inherent in the PPS, the PPS as proposed (aside from the oral med piece) is paying for a dose of ESA that is going to be severely cut. No one even mentions sub-q but between that and much more conservative dosing to reach far lower targets the PPS is probably over paying for EPO.

Rich you are adorable! It is a good sign, in that it must mean a sophisticated analysis of the PPS shows home dialysis will be more profitable than incenter for more people once the PPS takes effect.

Rich Berkowitz

Adorable? Was is my bare legs form our snorkeling and sppending time at the beach together?

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