After two months of ASN advocacy, led by the ASN Quality Committee, the Centers for Medicare and Medicaid Services (CMS) today, January 2, 2020, announced adjustments to the proposed Kidney Care Choices (KCC) Model’s basic design. The changes were originally called for by the ASN Quality Committee – just after the model’s unveiling – and were intended to correct a design flaw that made it impossible for many nephrology practices in multi-specialty practices to participate.
After two months of ASN advocacy, led by the ASN Quality Committee, the Centers for Medicare and Medicaid Services (CMS) today, January 2, 2020, announced adjustments to the proposed Kidney Care Choices (KCC) Model’s basic design. The changes were originally called for by the ASN Quality Committee – just after the model’s unveiling – and were intended to correct a design flaw that made it impossible for many nephrology practices in multi-specialty practices to participate.
The unintentional flaw was a requirement that the nephrology practice receive 50 percent of its income from nephrology services as indicated by its taxpayer identification number (TIN). However, at most integrated institutions and healthcare systems, the income of nephrology practices is aggregated under the same TIN as other practices like oncology, endocrinology, cardiology, and others, on tax returns. Very few, if any, of these TINs spanning many specialties would meet the requirement that 50 percent of their income be attributable to nephrology.
CMS states “this document expands upon eligibility requirements regarding revenue calculations and practices’ Tax Identification Numbers (TINs).” These changes apply to both the Kidney Care First (KCF) and Comprehensive Kidney Care Contracting (CKCC) Options of the KCC Model .
The primary change to the KCC Model’s Request for Applications (RFA) is as follows:
Original Language:
To be eligible to participate in the KCF Option, the practice will need to demonstrate that at least 50% of the practice’s total revenue from the previous 6 months comes from nephrology services; The practice must receive at least 50% of its Medicare payments for services furnished to beneficiaries with CKD, ESRD, or a functioning transplant.
Revised Language:
CMS will calculate this threshold based solely on the nephrologists from the practice who apply to the model to verify that at least 50% of the revenue for those self-identified nephrologists who apply comes from seeing beneficiaries with CKD, ESRD, or a functioning transplant. CMS encourages participation from larger practices or multispecialty practices, but still requires that at least 80% of nephrologists in the entity that have reassigned the right to receive Medicare payments to the entity must participate in the model.
This change should clear the path for more nephrology practices to apply by the January 22, 2020 deadline. CMS is encouraging practices that are uncertain if their practice meets all requirements to apply and enter into negotiations with the agency to determine if practice participation is possible. There is no penalty for withdrawing later this year before finalizing an agreement with CMS.
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