As we explained last week, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule on July 3, 2014 that will change how dialysis facilities are paid and how quality in the facility is measured. Last week we focused on the changes to the payment, and this week we focus on the quality changes.
The Medicare end-stage renal disease quality incentive program (QIP) reduces Medicare payments to dialysis facilities that do not meet certain quality standards. The idea, commonly known as pay for performance, is meant to encourage healthcare providers to improve the quality of care they deliver. CMS measures performance through a defined set of quality measures. Each year, every dialysis facility is given a total score based on its achievement of these quality measures as compared to the national average and the facility’s year over year improvement in the measures. If facilities don’t achieve a satisfactory performance score, they receive a reduction in payment ranging from 0.5% to 2%.
To align with CMS’s goal to evaluate healthcare providers based on the health status of patients and to incorporate the patients’ view of their dialysis facilities CMS is proposing the following changes to the QIP in 2017 and 2018:
Prevent Hospital Re-admissions for Dialysis Patients
CMS is proposing to hold dialysis facilities accountable for the percentage of their patients that are readmitted to the hospital, for nearly any reason, within 30 days of being discharged. The intent of this measure is to encourage facilities with higher than average readmissions, to go beyond their facility walls and work to improve communication with the hospital and the patients’ other health care providers.
Currently, dialysis facilities are penalized for patients who are prescribed an Erythropoietin Stimulating Agent (ESA) and have a hemoglobin <12g/dl. CMS proposes to remove this as a measure in the QIP. In the past, this measure was included to ensure that facilities were not prescribing too much of an ESA. However, very few facilities have patients who are taking an ESA and have a hemoglobin greater than 12g/dl so CMS believes the measure is no longer necessary. To ensure that facilities are still treating anemia with ESAs, when appropriate, CMS is proposing to penalize facilities that have a high number of patients who receive a blood transfusion. This measure is intended to ensure that facilities provide proper anemia management and do not subject patients to unnecessary blood transfusions, which pose risks that can make it harder for patients to find a kidney donor.
CMS proposes to review responses from the In-center Hemodialysis Consumer Assessment of Healthcare Providers and Systems (ICH CAHPS) survey and score facilities based on patients’ responses to questions related to their nephrologists’ communication and caring, the quality of their dialysis centers care and operations, and how well the facility provides information to patients. It would also include a score related to patients’ overall feeling about the nephrologist, dialysis facility staff and dialysis facility. The idea is to ensure that facilities are motivated to address issues of concern to patients in order to improve patients’ satisfaction and experience.
Screening for Pain and Depression
In 2018, CMS also proposes to require facilities to report that they have evaluated all patients for symptoms of depression and pain.
What do you think about these changes? Do these measures reflect how you judge the quality of care your dialysis facility provides? Share your comments with us. Also, if you are a current dialysis patient or a family member of a current dialysis patient, please take this brief survey so we can incorporate your viewpoints into our comments to CMS.