ASN Meets with CMS Administrator Tavenner, Other Top CMS Leaders

Bringing ASN’s perspectives on key issues and programs affecting patients with kidney disease, ASN President Bruce A. Molitoris, MD, FASN, and ASN Public Policy Board chair Thomas H. Hostetter met with top leaders at the Centers for Medicare and Medicaid Services (CMS) in June.

“Both ASN and CMS share the goal of delivering the best possible care to patients with chronic kidney disease (CKD) and end stage renal disease (ESRD),” Hostetter said.“This meeting was an opportunity to discuss recommendations ASN has for improving the good work CMS is already doing in various programs and to reiterate the society’s strong desire to serve as an objective, evidence-based resource for the agency as possible.”

Recently confirmed CMS Administrator Marilyn Tavenner participated in the discussion,joined by Director for Medicare and Deputy Administrator Jonathan Blum, Chief Medical Officer Patrick Conway, MD—who was also recently appointed as the Interim Director of the Centers for Medicare and Medicaid Innovation—Deputy Chief Medical Officer Shari Ling, MD, and Chief of Staff Aryana Khalid.

Blum will be speaking at ASN Kidney Week 2013 as the Christopher R. Blagg Endowed Lecturer.

The discussion covered a range of topics, including the potential rebasing of the ESRD bundle. The ASN leaders emphasized concern that rebasing the bundle not adversely impact ESRD patient care or quality outcomes, and that ASN wants to work with the agency to ensure monitoring of appropriate patient access and outcomes to maintain the quality of care the society has come to expect through the implementation of the bundle and Quality Incentive Program.

ASN reiterated that the ESRD bundled payment should cover the actual cost of providing services to beneficiaries, and that a rebased bundle must maintain the flexibility to preserve the physician-patient relationship and ensure that the most appropriate, personalized treatment is available to each individual. ASN continues to articulate concerns that CMS appropriately rebase the bundle in a manner that protects patient access to care (see article, above).

The Medicare Shared Savings Program was another focus of the conversation, particularly ASN’s recommendations for improving the ESRD Seamless Care Organization (ESCO) Program. ASN placed special emphasis on the importance of strategies to promote transplantation in ESCOs. For most patients, kidney transplantation is the optimal form of renal replacement therapy; ASN concurred with CMS that increased transplantation rates are essential to achieving the Comprehensive ESRD Care Initiative’s goals. However, transplant candidates tend to be the healthiest patients and, by extension, the least costly and complicated dialysis patients. Given that patients who receive a kidney transplant are no longer attributed to an ESCO, ASN expressed concerned that there is an unintended incentive to not transplant patients who would be good candidates for care through ESCOs, and offered to collaborate with CMS to develop a solution to prevent this potential unintended consequence.

Table 1 summarizes the recommendations ASN made to CMS regarding the ESCO program.

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Tavenner and Blum were also interested in ASN’s recommendations regarding how to improve the care of patients with CKD in “general” Accountable Care Organizations, both in terms of quality measures and care delivery concepts. CMS leadership recognized that some of the greatest opportunities for savings in kidney care occur in the late stages of CKD—such as vascular access placement and consideration of home dialysis—and ASN anticipates further exchange with the agency on this issue in the future.

“I believe that this opportunity for dialogue and exchange of ideas with Ms. Tavenner and her colleagues at the highest levels of CMS leadership helped to solidify ASN as a thoughtful resource on all issues related to kidney care for the agency,” Hostetter said.“It is my hope that ASN can continue to build this relationship, with the ultimate goal of helping CMS continually improve the quality of care our patients receive.”