Creation of payment models is a critical component of the Executive Order on the Advancing American Kidney Health (AAKH) initiative issued by President Donald J. Trump on July 10, 2019. At the time this article was written, the Innovation Center of the Centers for Medicare and Medicaid Services (CMS) had only released the End-Stage Renal Disease (ESRD) Treatment Choices (ETC) Model, a mandatory model that tests using payment policy to drive higher rates of home dialysis and kidney transplantation. The proposed payment policies will affect the managing clinicians and dialysis facilities assigned to the model. The four voluntary models to accompany the ETC model were still to be released.
With a clear perspective of the breadth of what CMS proposed in the ETC model—and the overall AAKH initiative—American Society of Nephrology (ASN) President Mark E. Rosenberg, MD, FASN, submitted comments and recommendations developed by the ASN Quality Committee to CMS on September 16, 2019. The recommendations were developed with guidance from the ASN Council and input from numerous ASN members and in collaboration with other kidney community members. While ASN provided its own specific recommendations, ASN, the National Kidney Foundation, and the Renal Physicians Association also submitted a high-level overview outlining five areas for improvement in the model (See Table 1).