Demystifying Form 2728

Although nephrologists complete the “End Stage Renal Disease (ESRD) Medical Evidence Report Medicare Entitlement and/or Patient Registration” form (form 2728) 138,000 times per year, the form is underappreciated and surprisingly important (1). Form 2728 was born in 1973 out of necessity. The form is, primarily, a nephrologist's attestation to the Centers for Medicare & Medicaid Services (CMS) that a patient is eligible to receive the ESRD Medicare benefits, irrespective of age and based solely on his or her diagnosis (2). However, form 2728 is also a critical point of data collection for understanding the population of patients requiring kidney replacement therapy.

Aside from the expected patient demographics, form 2728 collects various diagnostic and care information, for example, primary and secondary diagnoses leading to ESRD status (boxes 14 and 16), aspects of pre-dialysis chronic kidney disease (CKD) care (box 17), and incident laboratory data (box 18) (3). These data, it turns out, are the most impactful.

CMS, the US Renal Data System (USRDS), and, under a CMS contract, the University of Michigan Kidney Epidemiology and Cost Center (UM-KECC) are the prime users of 2728 data. CMS uses the data to administer the ESRD program, for example, determining a patient's first day of dialysis. USRDS uses the data to evaluate and publish patient trends in its annual report. UM-KECC employs 2728 data in a wide variety of metrics to which both medical directors and dialysis facilities are held accountable. It is this last use case that is often underappreciated. For example, UM-KECC uses comorbidity data collected in box 16 for risk-adjusted metrics included in the Quality Incentive Program (QIP), 5-star program, and related dialysis quality metrics (4).

Form 2728 has several limitations of which nephrologists should be aware. First, the list of selectable comorbidities (box 16) and primary causes of renal failure (box 14) are chosen by CMS and are the only choices available. Second, after initial submission, there is only a 5-day window to update a patient's 2728 data (5). Third, CMS has no specific processes to gather feedback for the form. Suggested changes in data elements or processes must go through standard CMS advocacy pathways.

All of this means that the 2728 data may not easily capture the full complexity or intensity of a patient's illness. And the initial data selected persist over the entire duration of a patient's kidney replacement care, irrespective of disease progression. Given this, nephrologists and their care teams have an enormous opportunity to ensure that patients' form 2728 data are comprehensive, timely, and accurate (6, 7). Engaging the right processes and people to create a precise clinical picture of our incident dialysis patients is critical. To be sure, this effort is challenging, but form 2728 is our tool for painting that picture.