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.
The Centers for Medicare and Medicaid Services (CMS) released the proposed rule for the 2021 End-Stage Renal Disease (ESRD) Prospective Payment System (PPS) and Quality Incentive Program (QIP) on July 6. The proposed rule contains some of the nuts and bolts that run the Medicare ESRD program on the facility side. It contains numerous guardrails to protect kidney failure patients and provide them access to the best modalities.
Status Tool for 2017 Qualifying APM Participant and MIPS APMs DataNow Available
If you participate in the Merit-based Incentive Payment System (MIPS), you should have reviewed your 2017 performance feedback by now. The 2017 MIPS performance feedback, reflecting activities in performance year one of the QPP (2017), indicates if you will receive a negative, neutral, or positive payment adjustment in 2019. If you believe an error has been made in your 2019 MIPS payment adjustment calculation, you can request a targeted review until October 1, 2018. The following are examples of circumstances in which you may request a targeted review:
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.”
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.
You can learn more about the KCC Model of the AAKH initiative by joining a series of webinars being hosted by the Center for Medicare and Medicaid Innovation (CMMI). CMMI will be hosting a series of webinars to introduce the details of the CMS Kidney Care First (KCF) and Comprehensive Kidney Care Contracting (CKCC) Model Options and review the application process, which closes on January 22, 2020. The webinars are:
Today, the Centers for Medicare and Medicaid Services (CMS) released finalized 2017 performance data for the Quality Payment Program (QPP) that will be used to determine clinician reimbursement adjustments for calendar year 2019 – the first year for adjusted payments under the new program. CMS announced the preliminary data earlier this year, and now it is claiming “significant success and participation in both the Merit-based Incentive Payment System (MIPS) and Advanced Alternative Payment Model (APM) tracks” with the release of the finalized data.
The Kidney Care Choices (KCC) Model, also known as the “voluntary model”, is moving forward beginning April 1, 2021 – a delay from the original start date of January 1, 2021 – due to the Public Health Emergency (PHE). The Centers for Medicare & Medicaid Services (CMS) Innovation Center announced that in addition to delaying the start of the model, the agency will also provide a second window for applications in 2021 for new participants with a starting date for that group of January 1, 2022. Additionally, applicants approved for the April 1, 2021 start date will have the option to delay their start date to January 1, 2022 without penalty or having to reapply. Also covered in this announcement was an extension of the Comprehensive ESRD Care Model (CEC) until March 31, 2021, with financial adjustments for performance year 2020 due to COVID-19. The CEC created the ESRD Seamless Care Organizations (ESCOs) of which there are 33 nationally.
After a long period of consultation with ASN and others in the kidney community, Department of Health and Human Services (HHS) Secretary Alex M. Azar, II, yesterday unveiled the four voluntary kidney care payment options of the Kidney Care Choices (KCC) Model that are a part of the Advancing American Kidney Health (AAKH) initiative. ASN President Mark E. Rosenberg, MD, FASN, calls the AAKH initiative “a true game changer.”
The Centers for Medicare & Medicaid Services (CMS) updated its Quality Payment Program Look-Up Tool, yesterday on June 14th, to allow clinicians to view 2018 Merit-based Incentive Payment System (MIPS) eligibility and Alternative Payment Model (APM) Qualifying APM Participant (QP) data—in one place. Additionally, the look-up tool name was changed from the MIPS Participation Status Tool to the Quality Payment Program Participation Status Tool to reflect the changes CMS made.