NN&I - July 2010
Renal EconomicsSubscribe to our free eNewsletter at www.nephronline.comJuly 2010 Nephrology News & Issues 35 into electronic medical records (EMR) now. We have started a home hemo-dialysis program to complement our peritoneal dialysis program to provide additional modality choices to patients and enhance our revenue to the facil-ity with minimal investment. With the implementation of Accountable Care Organizations (ACO) in 2012, most dialysis facilities will have an oppor -tunity to team up with primary care physicians, hospitals, and other spe-cialists and provider groups to offer coordinated quality care for financial gain sharing without the fear of statu-tory limitations. Working in the bundle era With all the analysis and careful preparation we have brought to the introduction of the expanded bundle methodology, we continue to have serious reservations. Our company is owned by nephrologists and built on a commitment to physician direction. This law inserts dialysis providers into the decision-making process beyond traditional protocol and formulary development. We fear being subjected to the pricing policies of drug com-panies without any practical alterna-tives; facing case mix adjustments that do not adequately adjust; outlier pay-ments that are unlikely to reflect true unavoidable costs; and a quantum leap in transaction costs of all sorts with respect to data collection, billing and training. Yet the base dialysis bundle has been a source of substantial sav-ings to Medicare relative to general program growth. We believe CMS has a pharmacy cost problem, not a dialysis cost prob- lem. The bundle is primarily aimed at controlling the drug costat the risk of inadequately funding the dialysis treat -ment itself. Maybe it is riding the wrong horse. Acknowledgement We acknowledge the help of Edward J. Dowling in preparing this manuscript. References1. Mayne TJ Highlights of the CMS proposed rules for the prospective payment of dialysis, Nephrology News and Issues, October 2009 2. Bhat P, Sokolowski W, Bhat JG. Projected impact of the proposed "bundled" ESRD payment on a small dialysis organization. Nephrology News and Issues, June 2009 3. Bhat P, Sokolowski W, Bhat JG. Does the clini-cal case-mix adjustment component of Medicare's expanded bundled payment system predict costs of ESRD care? Poster, annual meeting of the American Society of Nephrology, October 2009, San Diego, Calif. 4. Bhat P, Bhat JG. The proposed rule for prospec-tive ESRD payment: Perspectives from a for-profit small dialysis organization. American Journal of Kidney Disease, Vol 55, No. 2 (February), 2010 231-233. 5. United States Government Accountability Office Report GAO-10-295, March 2010 6. available at http://www3.cms.gov/ ESRDPayment RenalEconomics_16.indd 35 6/17/10 3:12:07 PM
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