The US Centers for Medicare & Medicaid Services (CMS; Medicare) has issued its long-awaited final rule for dialysis patients. Entitled “Medicare Program; End-Stage Renal Disease Prospective Payment System,” (.pdf; 1.3MB) the final rule contains the “bundling” arrangement for dialysis services which becomes effective 1 January 2011. (Here’s the much easier to digest CMS fact sheet.) Under the new rule, Medicare will pay a single, predetermined fee for each dialysis treatment, covering the entire “bundle” of services (dialysis, supplies, drugs, and lab tests). As a result, the use of intravenous drugs to treat anemia—notably Amgen’s Epogen—will likely be sharply reduced.
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. Because Epogen is now part of the “bundle,” it will likely be underused and patients’ quality of life will suffer. While Medicare has set up adequate standards for quality of care—including maintaining patients’ hemoglobin levels between 10-12—it remains to be seen how these standards will be enforced. When my hemoglobin falls below 11.3, I’m wiped out; when it’s below 10, I’m virtually immobile and barely conscious.
Cheryl Clark, writing for HealthLeaders Media, cites CMS as saying, “the law requires CMS to reduce the payment rates to a dialysis facility by up to two percent if that facility fails to meet or exceed the established performance scores with regard to performance standards established for each quality measure.”
