Department of Health and Human Services (HHS) officials from the office of the Secretary, office of the Chief Technology Officer (OTC), Centers for Medicare and Medicaid Services (CMS), and the Innovation Center at CMS, came together for an HHS-wide Forum on the Executive Order on Advancing American Kidney Health (AAKH), especially the Kidney Care Choices (KCC) model on Thursday, November 7, at Kidney Week 2019.  The session was standing room only with a very engaged audience.

Nick Uehlecke, advisor to HHS Secretary Alex M. Azar, II, gave an overview, painting a picture of robust engagement and excitement across the department as the Secretary led the department-wide effort to create the AAKH initiative.  He was joined by Scott D. Bieber, DO, chair of the ASN Quality Committee, who detailed ASN’s involvement in the development of the initiative and the society’s commitment to seize the opportunity to transform kidney care presented by the initiative.

The heart of the session was led by Center for Medicare and Medicaid Innovation (CMMI) officials Kate Blackwell and Jason Heron.  They detailed the basic structure and payment mechanisms on the Kidney Care Choices (KCC) model – the voluntary model designed to complement the mandatory ESRD Treatment Choices (ETC) model.

On October 24, CMMI released the long-awaited Request for Applications (RFA) for the KCC model, which is comprised of the Kidney Care First (KCF) Option —the nephrologist/nephrology practice–only option—and the Comprehensive Kidney Care Contracting (CKCC) Options.  

In the KCF Option, nephrologists and nephrology practices will receive adjusted capitated payments for managing Medicare beneficiaries with CKD stages 4 and 5 and ESRD and will be eligible for upward or downward payment adjustments based on the quality of their performance and improvements in their performance over time. The KCF Option will include Benefit Enhancements such as application of the kidney education benefit, telehealth for home patients, home health, and hospice to enable nephrologists to strengthen care coordination for patients and will be a Merit-based Incentive Payment System (MIPS) Alternative Payment Model (APM) and an Advanced Alternative Payment Model (Advanced APM) beginning in 2021.

For the CKCC Options, nephrologists and nephrology practices must partner with transplant providers, and may partner with dialysis facilities and other providers and suppliers to become Kidney Contracting Entities (KCEs). KCE nephrologists will receive adjusted capitated payments for managing beneficiaries with CKD stages 4 and 5 and ESRD. The KCE will select a total cost of care accountability framework, and their payments under the model will be adjusted based on their performance on quality measures.

KCEs participating in the CKCC Options will be able to participate in the Graduated Option, the first year of which is modeled off of the CEC one-sided risk track in the CEC Model, or the Professional Option or the Global Option, both of which are based on the Professional Population-Based Payment and Global Population-Based Payment options of the DC Model. Each Option will use the same benchmark process, based on the prospective benchmark calculation used in the Professional Population-Based Payment and Global Population-Based Payment options of the DC Model for the standard Direct Contracting Entities (DCEs). The CKCC Options will be Advanced APMs beginning in 2021, except for the Graduated Option. The CKCC Graduated Option will be an Advanced APM in Level 2.  CKCCs will also include the same Benefit Enhancements.

Following a robust Q&A period, the session was rounded out with an update on transplantation policy by Sandeep Patel, PhD, from the office of the OTC, and nephrologist Jesse Roach, MD, of CMS.  The pair provided an overview of upcoming proposals and request for information (RFI) to provide more clarity and transparency in the procurement of organs and efforts to increase the supply of organs by increasing support and reducing barriers to living organ donation.