In a recent letter to the Centers for Medicare & Medicaid Services (CMS), ASN submitted comments on a proposed rule concerning the End-Stage Renal Disease (ESRD) Prospective Payment System, Quality Incentive Program, and End-Stage Renal Disease Treatment Choices (ETC) Model.  

“The ESRD Medicare Benefit and the ETC Model shape critical components of kidney care for the nearly 800,000 Americans with kidney failure, including more than 550,000 individuals who are dependent on maintenance dialysis—many of whom may not survive long enough to receive a live-saving transplant,” the letter points out.

ASN urged CMS to ensure the Substantial Clinical Improvement (SCI) criteria for the Transitional Payment for Innovative ESRD Equipment and Supplies (TPNIES) accounts for common sense solutions. Recognizing that there are barriers related to the use of items during the first few years after introduction, ASN recommends extending TPNIES to three years. The society also pointed out that there are no current policies to adjust the base bundle rate to account for new products. There is also the challenge raised by the definition and interpretation of substantial clinical improvement (SCI) criteria.

“Unfortunately, kidney diseases and kidney failure are more common among Black, Hispanic or Latinx, and Native or Indigenous Americans, Asians, Hawaiians and Other Pacific Islanders, people in lower income brackets, and the elderly; these are communities that also have been disproportionately affected by the COVID-19 pandemic, exacerbating existing disparities,” the letter states. “Providing direct care for patients with kidney diseases, ASN members are on the frontline to fight for better kidney health for all Americans and striving to eradicate these inequities.”

Improving the quality of dialysis delivered and/or reducing complications is also paramount, as ASN has noted. The society recommends increasing access through technical specifications that make home dialysis easier for people disadvantaged due to smaller homes, living alone, poor vision, challenges with dexterity or other physical limitations; or supporting modality longevity with a machine that helps more people dialyze at home with reduced drop out, including technologies that are easier for patients and care partners to use, more reliable than current machines, and able to boost communication between patients and care teams.  

“Black Americans are 3.7 times more likely to develop kidney failure than white Americans, and Latinx Americans are 1.5 times more likely to develop kidney failure than non-Hispanic or non-Latinx Americans. Further, Black, Indigenous, and Latinx Americans are less likely to initiate home dialysis when requiring dialysis for kidney failure or receive a kidney transplant,” the letter emphasizes. “These and other factors are why the Medicare ESRD program and the ETC Model, Kidney Care Choices (KCC) Model, as well as other models and reforms, are so vital for achieving health equity. ASN provides comments in this letter outlining support of these efforts as well as comments on other aspects of the ESRD PPS, QIP and ETC Model.”

ASN also recently sent a letter to the US Senate and a letter to the House of Representatives endorsing legislation in support of TPNIES, specifically legislation that would increase patient access to new products that may improve quality of life or help bring better value to the health care system.