On August 10, 2018, the Centers for Medicare & Medicaid Services (CMS) published updated regulations for dialysis facilities (1). The CMS guidance encompasses several modalities, with a focus on the locations where dialysis services are provided.
The new guidance reaffirmed CMS’ recognition of dialysis in a nursing home setting, making revisions to the State Operations Manual (Chapter 2, ESRD Facilities), adding section 2271A, titled “Dialysis in Nursing Homes.” This action affirmed that Medicare-approved ESRD facilities may provide dialysis services to skilled nursing facility (SNF) residents in the nursing home within an approved home training and support modality. These new requirements include operational, logistical, physical, and staffing guidelines for nursing home dialysis. What follows is a summary of the nursing home dialysis model.
First, let us briefly frame the term “subacute care dialysis” (SACD), which includes dialysis provided in SNFs. Dialysis patients in such facilities may receive hemodialysis or peritoneal dialysis. Hemodialysis in these facilities can be either conventional thrice-weekly treatments or shorter treatments five or six days weekly. As the nursing home peritoneal dialysis population is small and delivery relatively straightforward, this article concentrates on hemodialysis in nursing homes.
While there are nearly 700,000 ESRD patients in the United States (2), the precise number of dialysis patients in nursing homes is unclear. However, using data from the U.S. Renal Data System and CMS, reliable estimates place the number at about 10% of the broader nationwide dialysis population—at approximately 70,000 (2, 3). With the rapid increase in the number of new ESRD patients in the >65 years age group, this number is sure to increase in the coming years.
U.S. Renal Data System, USRDS 2016 Annual Data Report: Atlas of Chronic Kidney Disease and End-Stage Renal Disease in the United States, National Institutes of Health, National Institute of Diabetes and Digestive and Kidney Diseases, Bethesda, MD, 2016.
CMS Survey and Certification Letter. Home dialysis and self/home dialysis training in LTC facilities. Ref: S&C: 04-24. March 2004.
Stephens M, et al.. High costs of dialysis transportation in United States: Exploring approaches to a more cost-effective delivery system. J Health Economic and Outreach Res 2013; 1:134–50.