ASN Weighs in on ESRD Treatment Choice Model in Letter to CMS

Reducing the benchmark for the combined home dialysis and transplant rate and allowing for incremental achievement of the benchmark, incentivizing and investing wisely to ensure needed practice transformation, and delaying the start date of the ESRD Treatment Choice Model (ETC) until April 2020 are among the recommendations for adjustments to the model set forth in a letter sent to CMS Administrator Seema Verma on behalf of ASN and its members from President Mark E. Rosenberg, MD, FASN.

“ASN believes the goals of the AAKH initiative and the proposed ETC model represent a necessary paradigm shift in the kidney care delivery system that has existed for nearly half a century,” the letter states. “In order to realize this transformative goal and avoid the unintended consequences described... in this letter, we believe there must be both appropriate adjustments that are not overly punitive and more up-front investment to make possible the desired achievements in increased home dialysis and transplantation rates.”

Following are additional recommendations ASN believes are essential for ensuring the success of the ETC Model:

  • Empowering Patients and Care Teams to Evaluate the Range of Treatment Options Using Shared Decision-Making Tools and Incorporating Additional Risk Adjustment to Mitigate the Risk of Non-Patient Centered Decision Making, e.g., for the housing-insecure population
  • Guaranteeing Access to Quality Home Dialysis Programs by Aggregating at a Geographic Level Such as a Hospital Referral Region (HRR)
  • Incentivizing and Investing Wisely to Ensure Needed Practice Transformation
    - Reducing the Performance Payment Adjustment (PPA) to a Level Comparable with the ESRD Quality Incentive Program (QIP)
    - Investing in the Home Dialysis Payment Adjustment (HDPA) at 3-5 Percent Annually for the Life of the Model
    - Making the Model an Advanced Alternative Payment Model (AAPM)
  • Increasing Access to Transplantation by Incorporating Adjusted Transplantation Rates as an Outcome

ASN also asked CMS to provide the opportunity for a second round of comments and to issue proposed rulemaking each year to include “evaluations of the program and adjustment for ‘lessons learned’ as the model progresses.”

Please view the full letter for more information.