ASN, the National Kidney Foundation, and the Renal Physicians Association Send Joint Response to CMS Regarding ESRD Treatment Choice Model

By David White

In a joint letter to the Centers for Medicare and Medicaid Services Administrator (CMS) Seema Verma, ASN, the National Kidney Foundation (NKF), and the Renal Physicians Association (RPA) laud the Trump administration for its “ambitious agenda for kidney health” and identify five principles the organizations state will lead to “better patient outcomes that should be supported in the proposed ETC Model.”

The following five principles are included in the organizations’ letter to CMS:

  • Establishing patient-centered targets, benchmarks, and risk adjustments that ensure there are guardrails in the Model for patients with contraindications or insurmountable barriers for home dialysis or transplant. In addition, correctly risk adjusting the patient population that is to be placed in the denominator for evaluating ETC Participants – clinicians and dialysis facilities – would empower them to make truly shared, patient-centered choices.
  • Empowering patients and care teams when evaluating treatment choices. The model should encourage the use of shared decision-making tools by patients and their care team when educating and evaluating kidney replacement therapies (KRTs).
  • Guaranteeing access to home dialysis programs. Enhancing patient access to kidney failure treatment choices and the education needed to properly evaluate those choices) is a key goal of the ETC model that we support. However, ensuring reasonable patient access to a home dialysis program does not require that every dialysis facility offer a home dialysis program.
  • Incentivizing and investing wisely in the proposed model. We believe the model must balance appropriate adjustments that are not overly punitive while providing more up-front investment to make possible the desired achievements in increased home dialysis and transplantation rates. The truly significant savings to Medicare under the proposed model derive directly from improved outcomes, less hospitalization, more transplantation, and fewer years of dialysis – results that will require investment in order to achieve.
  • Providing ETC participants the time to properly prepare for the model and the opportunity to comment as the model progresses. We believe the success of all participants in the model would be enhanced by providing more time before commencing the ETC Model date for stakeholders to prepare starting April 1, 2020. We also believe the success of the model would be enhanced by using the rulemaking process throughout the life of the model.”
     

“We strongly support the goals and objectives of the AAKH initiative and stand ready to work with the Center for Medicare and Medicaid Innovation to support these five principles in all facets of the proposed ETC Model,” the letter states.

For more information, please read the full joint letter.

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In a joint letter to the Centers for Medicare and Medicaid Services Administrator (CMS) Seema Verma, ASN, the National Kidney Foundation (NKF), and the Renal Physicians Association (RPA) laud the Trump administration for its “ambitious agenda for kidney health” and identify five principles the organizations state will lead to “better patient outcomes that should be supported in the proposed ETC Model.”

The following five principles are included in the organizations’ letter to CMS:

  • Establishing patient-centered targets, benchmarks, and risk adjustments that ensure there are guardrails in the Model for patients with contraindications or insurmountable barriers for home dialysis or transplant. In addition, correctly risk adjusting the patient population that is to be placed in the denominator for evaluating ETC Participants – clinicians and dialysis facilities – would empower them to make truly shared, patient-centered choices.
  • Empowering patients and care teams when evaluating treatment choices. The model should encourage the use of shared decision-making tools by patients and their care team when educating and evaluating kidney replacement therapies (KRTs).
  • Guaranteeing access to home dialysis programs. Enhancing patient access to kidney failure treatment choices and the education needed to properly evaluate those choices) is a key goal of the ETC model that we support. However, ensuring reasonable patient access to a home dialysis program does not require that every dialysis facility offer a home dialysis program.
  • Incentivizing and investing wisely in the proposed model. We believe the model must balance appropriate adjustments that are not overly punitive while providing more up-front investment to make possible the desired achievements in increased home dialysis and transplantation rates. The truly significant savings to Medicare under the proposed model derive directly from improved outcomes, less hospitalization, more transplantation, and fewer years of dialysis – results that will require investment in order to achieve.
  • Providing ETC participants the time to properly prepare for the model and the opportunity to comment as the model progresses. We believe the success of all participants in the model would be enhanced by providing more time before commencing the ETC Model date for stakeholders to prepare starting April 1, 2020. We also believe the success of the model would be enhanced by using the rulemaking process throughout the life of the model.”
     

“We strongly support the goals and objectives of the AAKH initiative and stand ready to work with the Center for Medicare and Medicaid Innovation to support these five principles in all facets of the proposed ETC Model,” the letter states.

For more information, please read the full joint letter.

Date:
Tuesday, September 17, 2019