CMS only pays for three days’ worth of dialysis, which some say has been a disincentive to more frequent and home-based treatments. Industry professionals are anticipating the results of a major study undertaken by the National Institute of Diabetes and Digestive and Kidney Disease, which examines the efficacy of more frequent dialysis. The results of the study will be made public at the American Society of Nephrology annual meeting in mid-November.

Race adjustor
In its proposed rule, CMS included 18 case-mix adjustors that would enable clinics to justify higher treatment costs for different patient groups. Industry feedback to this portion of the rule reduced the number to eight new adjustors and increased the base rate.

An adjustor for a patient’s race or ethnicity did not make it into the final rule; an element providers believe should be a part of the PPS. DaVita’s Zumwalt says dialysis patients who are black are more expensive to treat and make up about 35 percent of the dialysis population.

“It’s well documented that African-American patients require 14 percent more pharmaceuticals, Vitamin D and Epogen to obtain the same outcome as a Caucasian individual,” she says.

Zumwalt says that in its own analysis, CMS writes that facilities in the Southeast will see the biggest drop in revenue, a region where the patient dialysis population is more than 60 percent black.

“We have a lot of heartburn over that because we know what’s driving it,” says Zumwalt. “The system doesn’t have a mechanism now to correct it.”

Some industry experts speculate that CMS left out the race adjustor because it was a touchy and politically charged decision to make. In the final rule, the agency does state that it plans to invest resources into studying clinical or biological factors that increase the cost of care for certain groups, such as women and blacks.

QIP: A penalty system?
In addition to changing how facilities are paid for dialysis, MIPPA of 2008 also calls for a program aimed at improving the quality of care among dialysis providers. Set to begin on Jan. 1, 2012, the Quality Improvement Program is significant in itself – it’s the pioneering Medicare pay-for-performance program.

The proposed rule outlines three dialysis quality measures, which will be measured on a facility-wide basis of the patient population and compared to the national average. The three measures are hemoglobin above 12 grams per decileter (g/dL), hemoglobin below 10 g/dL and urea reduction ratio equal or greater than 65 percent. Under the QIP, facilities that fail to meet or surpass these measures will see as much as a 2 percent reduction in payment rates.

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