Sunday, October 20, 2013

The ESRD Payment Cut - A Constructive Approach

The most well thought out analysis of the ESRD Payment Cut was recently published by Mark Neumann for Nephrology News and Issues.

I have known and interacted with Mark for many years and I respect his balanced approach to most things. But, my respect for him grew even more after reading a commentary he published recently Oct 2, 2013. I am quoting:

"On July 19, I posted an entry to my blog on NephrologyNews.com headlined, “Bundled payment cut: Time to get to work.” I suggested that the dialysis industry roll up its sleeves and develop a constructive response to the 12% pay cut being proposed by the Centers for Medicare & Medicaid Services for dialysis treatment. Professional advocacy groups and patient organizations had two months; make it count.

The payment cut wasn’t a CMS initiative; two investigational reports recommended the agency reduce the composite rate to account for a 30% drop in the use of injectable drugs, primarily Epogen, since 2007. Congress sealed the deal with the American Taxpayer Relief Act of 2012, requiring the agency to do it.

So while the cut was here to stay, the industry had an opportunity to spell out its ramifications not only in dollars and cents, but also in terms of the impact on patient services. Would special programs have to be cut, fewer nurses be hired?

Not everyone, in my view, took the high road. Asking patients to influence the outcome unleashed written comments to CMS (see more at www.regulations.gov)  like, “I am getting sick & tired of the government taking things away from people when they need it…you guys don't give a damn about people.” Or, simply, “I support stopping the 9.4% medicare cut for dialysis payments (sic) that are to start in 2014.” Likewise, asking Congressmen to backtrack on their votes by ordering CMS to make the cut —then criticizing the agency for doing it—smells of the influence of lobbying."

Mark goes on...

"Ultimately, as Kidney Care Partners said in its comments, we need to figure out a way to make that magic elixir, ESAs, not a bargaining tool. Pay dialysis centers based on the cost of providing a dialysis treatment, and pay them a fair price for the cost of providing drug therapy. It shouldn’t be that hard to do."

The point is that having embraced bundling and having benefited financially from it, dialysis companies cannot now say they won't accept their end of the bargain - a reduction in the bundled rate as their cost (from savings in ESAs and other injectables) go down. Rather, they need to rally around a model that pays for the true cost of dialysis plus a margin.