ASN Policy Q&A on the Advancing American Kidney Health initiative and the Nephrology Payment Models Part 3

The American Society of Nephrology (ASN) Department of Policy and Government Affairs team has received numerous questions from interested members on the proposed payment models arising from the Executive Order on Advancing American Kidney Health , the ESRD Treatment Choices (ETC) model and the and Kidney Care Choices (KCC) model.  This Kidney News Online series aims to share these questions and answers with the broader ASN membership. Please also see parts 1 and 2 of this series for more background information.

In addition, ASN and the National Kidney Foundation (NKF) will be hosting a webinar to help you evaluate which participation pathway is best for your practice. The webinar will take place next Tuesday, December 17, 1:30-3:00 pm ET and you may register here . The webinar will be recorded and posted online for viewing.

1. Is it true that the mandatory ETC model is now being pushed back by up to three years?

No.  The Centers for Medicare and Medicaid Innovation Center (CMMI) confirmed in comments at a kidney community event recently that delaying the model for up to 3 years is not their intention—and in fact, CMMI is working on finalizing it as soon as possible with no intention to shelve the model.

CMMI is required to list any rules that have been proposed but not been finalized within a certain timeframe on a “long-term agenda,” with a deadline of three years to finalize the rules.  Thus, listing the ETC model on the long-term agenda with a deadline in July 2022 is best understood as a formality, as opposed to a reason to believe that the final rule won’t be released until July 2022.
 

2. I am trying to determine if the payment options of the voluntary KCC model—particularly the Kidney Care First (KCF) program—are right for me and my practice. How can I make that determination?

We would encourage you to apply for the program by January 22, 2020.  Applying is free and there is no penalty to withdraw before making any final commitments, which would come later in 2020.

The benefit of applying is that it enables you to have more detailed conversations with CMMI about how the model can work for your practice—which they are not able to do unless you take the first step of applying.

CMS is encouraging interested practices to apply before January 22, 2020 to the model or models that you believe is/are appropriate. Even if all of your numbers for eligibility are not met regarding income mix or patient population size, CMMI wants practices to apply so the agency can work with you to aggregate with other practices or use other measures besides your taxpayer identification number (TIN) to fit. 
 

3. I believe that I will meet the necessary numbers for dialysis patients, but I am concerned that I will not achieve the same levels for CKD patients. How do I solve this? Or vice versa?

As stated above, CMMI realizes that some practices may have a sufficient number of patients with CKD and not a sufficient number with kidney failure or vice versa.  They have asked ASN to convey to you that you should still apply if you are interested in one of the KCC model payment pathways.  They stand ready to work with you on ways to achieve the necessary numbers through aggregation.

Again, there is no penalty if you apply and withdraw later in 2020.
 

4. I am concerned about the use of the NQF #0018 measure “Controlling High Blood Pressure” and other suggested possible metrics.

First, this hypertension metric is not recommended for use in ESRD patients and CMMI will not be applying it to those individuals.  Second, on p.62 of the Request for Applications , CMMI discusses other metrics the agency is developing for use in the model.  So, again, applying allows you to enter into discussion with the agency on all of these measures.
 

5. Where can I get more information to help me decide whether to join a model track?

The best way to get detailed information about whether a model track is right for you is to apply to CMMI by January 22, 2020.  You can then have specific conversations with CMMI that will help inform your decision IF you apply – and you can always decide not to move forward.

In the meantime, ASN and the National Kidney Foundation will be hosting a CME webinar to provide more information on the payment models. The webinar will take place next Tuesday, December 17, 1:30-3:00 pm ET, and you may register here. The webinar will be recorded and posted online for viewing afterwards.
 

If you have additional questions that you would like to see answered in the next article, please contact the ASN Department of Policy and Public Affairs team at policy@asn-online.org .

Please also share your questions with us here at ASN at policy@asn-online.org .