CMS Final Rule for 2015 Holds No Surprises

Mark Lukaszewski
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On Friday, October 31, 2014, the Centers for Medicare & Medicaid Services (CMS) released its 2015 End-Stage Renal Disease (ESRD) Prospective Payment System (PPS) and Quality Incentive Program (QIP) final rule for calendar years 2017 and 2018. This article provides a basic overview of the key takeaways of the rule.

After close inspection, ASN has concluded that the final rule did not contain any unexpected adjustments to the ESRD PPS or QIP and does not differ substantially from the proposed rule. The society determined it is likely that the 2015 rulemaking cycle will have a more pronounced effect on the program, as CMS is expected to provide further clarity on how new drugs may be added to the bundle, as well as make changes to the low-volume adjuster.


CMS finalized every aspect of the Protecting Access to Medicare Act (PAMA) pertaining to the ESRD PPS, including setting the base rate at a 0.1 percent increase from 2014 and delaying the inclusion of oral-only drugs until 2024. CMS noted that it believes the agency has the authority to add new services to the bundle, an issue that has recently been debated within the kidney community.

CMS addressed the provision of dialysis beyond the standard three times per week, restating its position that facilities must furnish medical justification for more frequent dialysis, and that dialysis modality choice does not constitute medical justification. The agency also stated that while it is not changing its policy regarding payment for drugs that are included in the PPS but are furnished for the treatment of ESRD, it recognizes that there is ongoing concern regarding patient access to prescription medications. CMS is considering various alternatives for dealing with this issue and plans to put out guidance in the near future.

Quality Improvement Program

In terms of the QIP, CMS finalized a proposal to implement a risk-standardized 30-day all-cause hospital readmissions (SRR) measure. ASN strongly supported this measure in concept but recommended against finalizing the measure owing to numerous concerns with the measure and methodology as designed. Notably, the National Quality Forum voted against the SRR measure when it was considered for endorsement this fall.

On a more positive note, CMS decided against adding a new measure to assess conditions treated by oral-only drugs, which is consistent with ASN’s encouragement to utilize a few highly meaningful measures rather than adding more watered-down measures. In addition, CMS finalized its proposal to remove the “Hgb >12 g/dL anemia management measure,” a change ASN has supported for several years because the measure is topped out.

ASN, together with the greater kidney community, will continue to work together with CMS in order to make sure that the measures being developed guarantee the highest quality care possible for the millions of Americans with kidney disease. To learn more about this issue, or to read the ASN comment letter to CMS, please visit the ASN advocacy page at