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November 13, 2017

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Mark@NN&I

Bill, this is an important issue. What the MACs are doing here administratively is logical: creating a uniform policy on more frequent dialysis so claims are treated the same way across the country. Because of inconsistencies from one MAC to another, dialysis providers have submitted claims in "softer" jurisdictions to get paid for more frequent dialysis. That's gaming the system, and the MACs now want to close that loophole.

The proposed language turns more frequent dialysis into a temporary treatment for a complication of ESRD. So the MACs are not banning it, but they are defining its usage to minimize Medicare fraud and abuse. What needs to be shown is evidence that CONTINUAL mfd benefits patients: every other night nocturnal, short daily, etc. so that the MACs can add those definitions to the rule.

It's a great opportunity for the patient advocacy groups to get together and let CMS know how important it is to have an alternative to thrice weekly HD.

Dori Schatell

We have only BEGUN the fight for the hearts and minds of new dialyzors. Of COURSE they are "choosing" standard in-center HD at a rate of 90%. They are SCARED when they need to make a modality choice, and we don't help them deal with their fear.

And, their nephrologists (just 6% of whom would choose standard in-center HD for themselves) can bill for 20 patients in an hour x 3 or 4 shifts per day x two schedules (MWF/TRS) per week in-center, and are lucky to fit in 3-4 patients in an hour at home. They make MUCH more money on in-center HD than on home treatments. So, patients who ASK for home treatments are reasonably likely to get them--but the rest end up in-center.

Both of these issues are fixable, and while you may be giving up the battle to get more folks home on better dialysis, I am not. Yes, we need to optimize in-center HD. Better dialyzers and more attention to ultrafiltration rates will help that. But, meanwhile, Transitional Care units are starting up, more attention is being devoted not just to education but to assisting the emotional adjustment of new patients, and home HD will continue to grow, with or without the MACs' help.

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