How to Give your Input to Medicare

Input due to Medicare by Dec. 16, 5 p.m. EST

By law, Medicare staff must consider your comments when preparing the final rules for bundling. The deadline is Dec. 16, 2009. Here’s how to comment:

1. Online at this website.

2. By mail to arrive before Dec. 16 at:

        Centers for Medicare & Medicaid Services
        Dept. of Health and Human Services
        Attention: CMS-1418-P, P.O. Box 8010
        Baltimore, MD 21244-8010

Everyone has the opportunity to give input to Medicare on bundling, to make it the best payment program it can be. Patients, family members, caregivers and those affected by kidney disease have a significant perspective and Medicare wants to hear from them. There are not many dialysis providers in the country like Northwest Kidney Centers; we are considered a “small dialysis organization”, we are community-based, and we are not-for-profit. It’s important to make our voices heard!

Medicare is required to consider all comments as it finalizes bundling rules. We expect the final rules to be released in summer 2010 to prepare for implementation in January 2011.

What to comment on

Feel free to express your opinion about any aspect of the bundle. At NKC, we appreciate these elements of the proposal:

• Use of a “treatment” rather than a time period for bundle payment, just like the current method for payment.
  
  
• Allowance for more than three hemodialysis treatments per week with medical justification.
  
  
• Excluding the costs of nephrology care and hospital care from the bundle of expenses that dialysis units will have to pay for.

We are most concerned about the proposed:

• Requirement that dialysis units pay for laboratory tests for patient conditions that are unrelated to kidney failure. We urge Medicare to include in the bundle only the lab tests which absolutely must be associated with dialysis care – and to make sure there is enough money in the bundle payment based on current and accurate costs for these services.
  
  
• Inclusion of oral drugs from a pharmacy, like phosphate binders, in the bundle. They can be expensive and are now covered under Medicare Part D. If included, make sure there is enough money in the bundle payment based on current and accurate costs for these services.
  
  
• Payment restrictions on home therapy. Medicare should fund the training for patients to learn how to safely go home, wherever they are in their dialysis journey.

Suggested format for comments

Explain who you are. “I am a dialysis patient from Seattle.” “I dialyze at a nonprofit dialysis center, one that is considered a small dialysis organization.” “I am a nephrologist who practices in Seattle.” “I am a volunteer at Northwest Kidney Centers.” “I am a dietitian in a dialysis program that serves 1,350 patients in the Northwest.” You may state your association with NKC or not.

Tell your story. “I have been on dialysis for three years.” “I am a peritoneal dialysis patient and this is why I like home therapy.” “As a nephrologist, I use laboratory tests as a primary tool in my practice.”

Acknowledge what you like. It is always respectful to start with a thank you. “Thank you for using a per-treatment method of payment and allowing payment for more than three-times-a-week treatment due to medical need.”

Tell what troubles you about the proposed bundling rules and offer suggested changes. Be specific in your proposed solution. For example: “Please ensure that the bundle includes a limited list of laboratory tests used specifically in the treatment of kidney failure, and that tests for other purposes may be billed separately.” “Ensure adequate funding is in the bundle based on current and accurate costs.”

Stay in touch
If you wish to share the comments you make to Medicare with NKC or have questions, send them to bundling@nwkidney.org.


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