NN&I - July 2010
Renal Economics 40 Nephrology News & Issues July 2010Subscribe to our free eNewsletter at www.nephronline.com bundled payment system will decrease reimbursement further for these rural hospital-based units by decreasing the low-volume definition to less than 3,000 treatments per year and eliminat -ing rural facility payment adjustments (Leavitt, 2008). Considering the lack of buying power these small facilities face compared to the large dialysis compa -nies, the hope of continuing this ser -vice in these rural areas is diminishing. CMS has been a very strong propo-nent of patient choice and has man-dated that patients be given informa -tion regarding their dialysis treatment options. In the proposed rule, CMS states that it wants to encourage the provision of home dialysis, and we com-pletely supports that position. However, eliminating the Method II option will effectively eliminate the staff-assisted home dialysis option. The irony here is that by using this billing mechanism to provide home dialysis, it actually costs CMS less than an in-center treatment. As part of our commitment to support a patient's right to choose their method of treatment, despite being a relatively small chain, we provide not only in-center hemodialysis, but also home peritoneal (PD) training, home hemo -dialysis training, staff-assisted home hemodialysis, and nocturnal dialysis. RCP, along with many other pro -viders, consider DME Method II to be a critical component of total patient choice. There is a Medicare patient population that has a vital need for staff-assisted home dialysis, and we have urged CMS to continue to support them by maintaining DME Method II. NN&I: There has been a lot of dis-cussion surrounding the negative posed elimination of the Method II for home therapies. Many individuals with ESRD, either prefer or truly need to dialyze at home but have no one to assist them. Staff-assisted home hemodialysis is possible because the uniqueness of the Method II supply bill-ing mechanism enables beneficiaries, with secondary private insurance that includes nursing coverage, the oppor -tunity to dialyze at home and have the cost of their nurse covered under their insurance. This is in contrast to the daily Method 1 billing, which includes a nursing component. Consider a young child who may be overwhelmed in a clinic or a per -son who is difficult to transport due to being incapacitated as the result of stroke. For patients such as these, and for many others, this billing mecha-nism is the difference that allows them to receive treatment in the comfort and safety of their own homes. NN&I: Is the bundled payment con-cept a good one for improving dialysis? Lugo: Renal CarePartners supports the Centers for Medicare & Medicaid Services on its efforts to implement a modernized, fully-bundled payment system. We are a company that from inception has focused its efforts on patient choice and properly educating our patients on their treatment alter -natives. However, we do have concerns about the possible effects of the pro-posed bundle on smaller dialysis orga-nizations that do not have the admin-istrative and technological resources at hand to properly implement such significant change to the current reim -bursement rules. NN&I: How do you anticipate the bundle will affect a patient's right to choose their method of treatment? Lugo: One of the most pressing con-cerns regarding the bundle is the pro-Preparing for the bundleAt what point is the financial burden going to be too much for these small rural hospitals to carry? The result will be thousands of patients without the health care services needed to sustain their lives. Resources CMS Office of Public Affairs. (2009). Medicare pro-posed payment system for end-stage renal disease would reduce spending, improve quality. Retrieved on May 25, 2010 at http://www.cms.gov/apps/ media/press/factsheet.asp?Counter=3515&intNu mPerPage=10&checkDate=&checkKey=&srchTyp e=1&numDays=3500&srchOpt=0&srchData=&ke ywordType=All&chkNewsType=6&intPage=&show All=&pYear=&year=&desc=&cboOrder=date. Leavitt, M. Report to Congress: A design for a bundled end-stage renal disease prospective pay-ment system. 2008. Retrieved on May 26 2010 from www.cms.gov/ESRDGeneralInformation/ Downloads/ESRDReportToCongress.pdf. As a 20-year veteran in the dialysis industry, Orestes Lugo, CEO and president of Renal CarePartners, says he is not a stranger to the effects legislative intervention can have on a dialysis provider's ability to administer patient care. As the final rule on a fully-bundled ESRD payment system approach- es, he shares some thoughts with NN&I regarding the possible impact of the proposed legislation. RenalEconomics_13.indd 40 6/16/10 6:43:31 PM
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