After two years of diligent efforts by the American Society of Nephrology (ASN) and other members of the Alliance for Home Dialysis, the provisions of the CHRONIC Care Act were signed into law after being included in the two-year budget agreement passed in February. The CHRONIC provisions authorize, among other items, a home dialysis patient’s monthly clinical visits to be conducted via telehealth with the home as an originating site. ASN and others supported the inclusion of telemedicine provisions in the recent congressional budget deal to pave the way for greater use of the technology and to boost access to care while reducing costs.
While the legislative success was widely applauded by ASN and other members of the Kidney Community, that was just part of the story. The other part has been playing out on the regulatory side in a choreographed dance between ASN and peer societies on one side and with the Centers for Medicare and Medicaid Services (CMS) on the other. Perhaps more accurately, the band was warming up and the participants were making their introductions before CHRONIC became law, but now the ball is in full swing.
Beginning several months back, ASN and the Alliance were making plans to visit CMS to make the case in-person that the dialysis access site of home dialysis patients could be safely examined via telehealth – something the law now allows in two out of three monthly exams. That meeting took place on Wednesday, February 21. Leading this effort for ASN was Beckie Michael, DO, FASN, who has been conducting telehealth exams for both peritoneal and hemodialysis patients since 2015 in conjunction with hospitals in rural and underserved communities.
“I believe that the ability to use telehealth technology to provide two out of three monthly nephrology visits for all home dialysis patients, with their home or the dialysis unit being the originating site, will result in fewer missed monthly visits and more efficient use of patients' and providers' time. A remotely performed home visit will also provide the nephrologist the ability to evaluate the patient's home dialysis environment, which is usually only seen by the home dialysis nurse,” said Dr. Michael.
“My experience, and that of other nephrologists, demonstrates that hemodialysis and peritoneal dialysis access can be safely evaluated via video conferencing,” she added.
Dr. Michael was joined by three other nephrologists in the presentation: Dr. Vesh Srivatana representing the Rogosin Institute; Dr. Maggie Gellens representing Baxter; and Dr. Chester Amedia representing the Renal Physicians Association.
The presentation to CMS provided important questions for consideration with Dr. Michael and her colleagues engaging in a lively conversation and dialogue to help inform CMS. Some highlights were:
What are the clinically required elements of an access site inspection for a PD/HHD patient, and why are they important?
How are these elements able to be performed via telehealth?
How frequently do PD/HHD access sites have issues of infection or other complications?
What training do PD/HHD patients receive on access site care and monitoring?
As CMS proceeds to develop rules governing this issue, Dr. Michael, the ASN Quality Committee (charged with formulating positions on regulatory matters for review by the ASN Council), and other Alliance members will continue to dialogue with CMS on this and a host of other issues.