US dialysis providers have overused Epogen, the expensive drug for treating anemia. There’s no question whatsoever of that. While it hasn’t happened to me in more than 11 years of dialysis, I know it’s a problem—the dialysis providers were using it as a profit center, plain and simple.
Last week, the US Food and Drug Administration (FDA) announced there were “no risk-free doses of Epogen, Aranesp, and Procrit” and changed the drugs’ labels calling for lower dosing.
This week, Medicare proposed rescinding its requirement (.pdf; 500KB) that dialysis providers maintain patients’ hemoglobin levels above a mandatory minimum, hoping to lower use of Epogen. Currently, Medicare requires dialysis patients’ hemoglobin levels to be maintained above 10 g/dL. As I’ve written—repeatedly and consistently—I’m in trouble when my hemoglobin falls below 11.5 g/dL and almost totally incapacitated when it falls below 11 g/dL. In more than 11 years on dialysis, I’ve never had Epogen overprescribed. Ever. I know overuse of Epogen is a problem; hell, there’s money to be made in it. Or, rather, there was.
“Clinicians should use the lowest dose of ESA (erythropoiesis stimulating agent) sufficient to reduce the need for red blood cell transfusions,” Patrick Conway, chief medical officer at the Centers for Medicare and Medicaid (CMS) said in a media release.
On 1 January 2011, Medicare’s final rule for dialysis patients—the “bundling” arrangement (.pdf; 1.3MB)—took effect. No longer would dialysis providers be allowed to bill separately for dialysis and drugs like Epogen. There would be a single “bundled” payment made. Previously, Medicare paid a predetermined fee for dialysis services, but some drugs—like Epogen—were reimbursed separately. That system gave dialysis providers a financial incentive to overuse Epogen which increased the patients’ risk of heart attacks and strokes. Under the new rule, Medicare pays a single, predetermined fee for each dialysis treatment, covering the entire “bundle” of services (dialysis, supplies, drugs, and lab tests).
Take the Medicare “bundle” (which applies to non-Medicare patients with private insurance, like me) and add in the proposal to rescind mandatory minimums for dialysis patients’ hemoglobin levels, and this very bad. Blood transfusions are sufficiently risky to make this incredibly bad policy.
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