CKCC Model Updates Seek to Mitigate RTA Effects

Following several calls for action by ASN, the Renal Physicians Association (RPA), and other community organizations, the Center for Medicare and Medicaid Innovation (CMMI) announced policy changes and updates on April 16, 2024, pertinent to the Comprehensive Kidney Care Contracting (CKCC) model, including changes to address the effect of the Retrospective Trend Adjustment (RTA) on the model and associated program modifications.

In the CKCC model, CMMI provides nephrologists with a “benchmark” (or baseline funding number) that is the government's projection for what the total health care spending is expected to be during that year for an individual patient with kidney disease. Nephrologists invest in services and staff to enhance patient care and outcomes, comparing their expenditures against this benchmark to determine their performance in the model. Participants can benefit from savings if spending is lower than what is set in the benchmark.

Last year, CMMI announced an RTA for benchmark years 2022 and 2023 due to inaccurate projections on its part, resulting in reduced reimbursement or paybacks for participants in the model long after care is provided. Alarmed by the idea of a retroactive change to the benchmark after investment in care, nephrologists, dialysis facilities, and value-based care organizations raised concerns that the unforeseen financial risk could cause some participants to drop out of the model.

In response to these concerns, ASN and RPA sent a letter to the Department of Health and Human Services and CMMI urging the Centers for Medicare & Medicaid Services (CMS) to narrow the risk corridors within the model or consider other proposals to ensure continued participation in the CKCC by nephrologists and other participants (1). In addition, ASN and RPA urged Congress to request that CMMI address the RTA's potential impact on model participation (2). ASN was concerned that the RTA decision would unfairly hurt participants and could potentially reduce enrollment in innovative care models, inhibiting access to care focused on delaying the progression of kidney diseases and expanding patient choice.

CMS announced that it plans to make two policy changes for performance year (PY)2024 for Kidney Contracting Entities (KCEs) (3):

1. There will be no changes to the financial methodology for payment years 2022 and 2023. However, after reviewing updated data, CMMI intends to update the CKCC model risk corridors by making them narrower for both the chronic kidney disease and end stage renal disease benchmark. These updates include:

   • KCEs are now responsible for absorbing the first 3% of any RTA adjustment.

   • KCE's responsibility decreases incrementally for adjustments between 3% and 6%, with CMS shouldering 50% of the adjustment.

   • The exposure for KCE's shared losses in a PY are capped at 4.5%.

2. KCEs will also be permitted to switch from the Global to the Professional option for the 2024 period, an option that was not available prior to this change. This change allows KCEs to project a shared loss in PY2024 based on the new RTA adjustments to mitigate its losses and share any potential savings or losses with CMMI.

ASN will continue to monitor the impact of these policy changes on CKCC model participants and advocate for the adoption of policies to promote access to kidney care that emphasizes earlier intervention, access to transplant care, and care coordination.