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AAMC Urges CMS to Phase in Cuts to Renal Dialysis Facilities

September 13, 2013—The AAMC Aug. 29 submitted a comment letter  to the Centers for Medicare and Medicaid Services (CMS) responding to the calendar year (CY) 2014 End Stage Renal Disease (ESRD) proposed rule.  In the letter, the AAMC urges CMS to phase in the 9.4 percent reduction to ESRD facilities required by the American Taxpayer Relief Act (ATRA, P.L. 112-240) over a several-year period rather than the proposed one year reduction.

The AAMC’s comments explain that hospital-based ESRD facilities at teaching hospitals tend to treat sicker, more complex patients who come to their facilities through emergency rooms and tertiary referrals. These patients often have multiple comorbidities, may not have insurance, tend to be older than patients treated at freestanding facilities, and are often bedridden with problems accessing transportation.  Hospital-based facilities also treat patients whom freestanding facilities routinely refuse to treat.

Rather than implement “drastic cuts” in one year, the AAMC encourages CMS to adopt a “significantly more gradual approach [that] would allow these facilities to develop a long-term plan for sustainability” and would protect vulnerable patient populations.

The AAMC also notes that the regulatory impact analysis CMS presented in the ESRD proposed rule did not display the impact of the cuts according to teaching status.  Given that the payment cuts CMS proposes to implement would have a “serious impact on teaching hospitals and the patients they treat,” the letter encourages CMS to include such an analysis in the final rule.

Regarding the proposed quality measures for the CY 2014 ESRD Quality Incentive Program (QIP), the AAMC submitted comments urging CMS to use National Quality Forum (NQF)-endorsed measures that also have been reviewed and recommended by the Measure Applications Partnership (MAP). Of the eight proposed measures that were added, expanded, or revised, only one has been endorsed by the NQF. In its comments, the association cites that similar ESRD measures were already NQF-endorsed and MAP-reviewed and therefore should be considered by the agency for use in the QIP.

The AAMC also strongly recommends that CMS only use measures in the QIP that have sufficient data to be scored on improvement points. If such data is not available, CMS should only require the measure to be reported and not scored as a clinical measure. 


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Washington Highlights, a weekly electronic newsletter, features brief updates on the latest legislative and regulatory activities affecting medical schools and teaching hospitals.

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Jason Kleinman
Sr. Legislative Analyst, Govt. Relations
Telephone: 202-903-0806