ASN joined several other health care professional societies in a meeting with the White House Domestic Policy Council and Office of Public Engagement to discuss clinical labor direct cost issues updates (as announced in the proposed CY 2022 Medicare Physician Fee Schedule (MPFS) rule) and its potential impact to patient care.
On October 7, 2021, ASN joined several other health care professional societies in a meeting with the White House Domestic Policy Council and Office of Public Engagement to discuss clinical labor direct cost issues updates (as announced in the proposed CY 2022 Medicare Physician Fee Schedule (MPFS) rule) and its potential impact to patient care. Suzanne Watnick, MD, FASN, and the Chief Medical Officer of Northwest Kidney Centers, represented ASN and presented comments on the potential impact of the proposed rule for kidney patients.
"Our dialysis patients comprise 1% of the Medicare population, but account for over 7% of the costs,” Dr. Watnick pointed out to White House representatives. “They are an incredibly vulnerable population, with half comprised of black, indigenous, and people of color, with high levels of comorbidity. They already have barriers to accessing critical outpatient care such as interventional radiologists and vascular surgeons, which was compounded by the pandemic. If patients cannot access this type of outpatient care, they will be hospitalized, resulting in increased cost to the system and negatively impacting their preferences. Most of our patients already have to go to dialysis thrice weekly, and they prefer to be home, rather than get hospitalized, where their quality of life will be compromised."
The Centers for Medicare & Medicaid Services (CMS) is proposing to update the clinical labor pricing for CY 2022, in conjunction with the final year of the supply and equipment pricing update, in the proposed MPFS rule. Initial analysis by ASN and other groups participating in the meeting shows updating the clinical labor rates is estimated to increase Medicare direct practice expense costs by 30%.
Due to budget neutrality constraints withing the MPFS program, the CY2022 scaling factor to account for this dramatic rise in direct practice expense costs is proposed to fall drastically to 0.44, from 0.59, an unprecedented rate. The proposal would be disproportionately distributed within the MPFS to services performed in the non-facility office. As Dr. Watnick noted, this could have unintended consequences that could undermine care for kidney patients.
ASN will continue to pursue adjustments to this proposal from the White House and CMS and keep ASN members updated.