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David White

The Executive Order on Advancing American Kidney Health (Section 8) directed the Secretary of Health and Human Services (HHS) to propose a regulation to remove financial barriers to living organ donation essentially:

ASN supported the proposed rule on Removing Financial Disincentives to Living Organ Donation issued by Health Resources and Services Administration (HRSA) of HHS and recommended further changes in its comment letter to the agency February 18, 2020.

David White

After much dialogue with the American Society of Nephrology (ASN) and other members of the kidney community, the Centers for Medicare and Medicaid Services (CMS) today clarified its guidance on deferring nonessential surgical procedures during the COVID-19 Public Health Emergency. The clarification clearly identifies Arteriovenous Fistulas, Arteriovenous Grafts, Peritoneal Dialysis Catheters, and intravenous catheters as planned procedures that are essential for establishing the vascular access that “is crucial for End Stage Renal Disease (ESRD) patients to receive their life-sustaining dialysis treatments.” Since the issuance of the original guidance, many ASN members have expressed their serious concerns that these procedures were being grouped with elective surgeries and, subsequently, being denied. Go to the ASN COVID-19 Response page for more information.

The long push for payment models to cross the silos of kidney care – chronic kidney disease (CKD), kidney failure and dialysis, and kidney transplant – continues with newly announced modifications to the implementation timeline of the Kidney Care Choices (KCC) Model, often referred to as the voluntary model.  The Center for Medicare and Medicaid Innovation (CMMI), which creates models and created the ESCOs, has extended the implementation period from March 31, 2021, until December 31, 2021. The effective performance year that was scheduled to begin April 1, 2021 will now begin January 1, 2022.

David White

The American Society of Nephrology (ASN) provided comments and critique of the proposed rule on Medicare Advantage (MA) for 2021 and 2022 on April 6, 2020. In 2021, by law, MA plans will be open to patients with kidney failure as opposed to those who were already enrolled in MA plans before advancing to kidney failure and remain enrolled after kidney failure.   

David White

After much urging from the American Society of Nephrology (ASN) and other members of the kidney community, the Centers for Medicare and Medicaid Services (CMS) issued a sweeping interim final rule on March 30 that provides multiple waivers the community requested to provide greater flexibility during the COVID-19 public health emergency (PHE). Of particular importance for ASN members, the rule greatly expands the use of telehealth in providing care to kidney patients – especially those with kidney failure receiving dialysis – for the duration of the PHE. CMS clarified that all evaluations of dialysis patients covered under the ESRD monthly capitated payment (MCP) may now be conducted via telehealth to protect those vulnerable patients and prevent further spread of the novel coronavirus 2019.

David White

The American Society of Nephrology has developed and released the Kidney Care First (KCF) Model Calculator for nephrologists and nephrology practices to help them evaluate how they might perform in the voluntary payment program. The calculator is a guide only and does not calculate every variable that a practice might face; however, it is designed to examine the difference in nephrology practice reimbursement in the status quo versus the KCF Option in the Kidney Care Choices (KCC) Model . This device is intended for practices already considering the KCF Option.

David White

Medicare has proposed changes to the payment rules for dialysis care and physician reimbursement for calendar year 2019. While several proposed changes are positive, one proposed adjustment to the Evaluation and Management (E&M) coding reimbursement structure has created serious concern and will be a priority in the American Society of Nephrology’s (ASN) comments to Medicare.

David White

Given the enormous impact of the 2019 Novel Coronavirus (COVID-19) on the healthcare system, the American Society of Nephrology (ASN) and other members of the kidney community have requested regulatory relief for clinicians and facilities on multiple fronts over the past few weeks. The Centers for Medicare & Medicaid Services (CMS) and other agencies within the Department of Health and Human Services are responding in kind. The following is an update for ASN members on several major steps of importance to nephrologists and their patients that CMS has taken, particularly:

David White

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.

David White

Thursday afternoon, November 1, Medicare released the final Physician Fee Schedule (PFS) rule containing some revisions to evaluation and management (E&M) codes in terms of documentation requirements but no changes in reimbursement levels for the next two years – but year three is another matter. 

The desire to reduce the documentation burden in E&M coding led CMS in July to propose a system that collapsed levels 2-5 of E&M into one reimbursement payment.  This move had negative implications for nephrologists and pretty much any physician practicing cognitive care with complex patients.  So, where did we end up and what do you need to know?