Federal Register - November 8, 2021

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Federal Register / Vol. 86, No. 213 / Monday, November 8, 2021 / Rules and Regulations reimbursement between PD catheter insertion and vascular placement within the Model. A voluntary track would allow participants to opt-in to further test broader and more comprehensive incentive payments. This track would allow for comparison of rates of PD
catheter placement within and outside the model, to evaluate whether the payment increase within the Model increased the rate of PD catheter placement. Others didnt think the incentive could be tested in the current model because ETC Participants have no ability to influence the behavior of surgeons or interventionalists who place PD catheters. However, these commenters noted they would be supportive of the incentive in another context.
Several commenters suggested that the Innovation Center should pilot bonus or increased payments for PD
catheter placement outside of the ESRD
PPS and MCP. These commenters recommended that the Innovation Center consider testing a bonus incentive payment for vascular surgeons, hospitals, and surgical centers that would increase reimbursement for PD catheter placement commensurate with reimbursement provided for AV
Fistula reimbursement. According to the commenters, this incentive payment should not be budget neutral to the ESRD PPS or the MCP, but instead should be viewed in the broader context of physician, hospital, and outpatient surgical center reimbursement systems.
Other commenters suggested financial options with less detail. One commenter suggested that CMS can encourage the placement of PD catheters by not only maintaining the reimbursement levels for office based placed catheters but increasing the reimbursement to levels that are on par with Ambulatory Surgery Center settings. Another commenter suggested paying PD catheter placement over timethat is, adding longevity payments so the surgeon gets payments for patients staying on PD at 90 days and 180 daysto align interests across nephrologists and PD providers.
Another commenter suggested a bonus payment per diagnostic related group DRG of new ESRD dialysis starts in the hospital who are leaving with a PD
catheter, including urgent PD. Lastly, another commenter suggested that PD
catheter placement be designed as an urgent procedure to be prioritized by the hospital under emergent procedures.
There were also several comments related to use of Innovation Center authority. The first such comment suggested that CMS propose including as ETC Participants those surgeons who bill for dialysis vascular access
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procedures including PD catheter placement identified based on certain CPT codes for example, 36818, 36819, 36820, 36821, 36825, 36830, 36831, 36832, 36833, 36838, 49324, 49418, 49421. According to the commenter, including these surgeons in the model would provide an incentive for the surgeons to partner with other providers to ensure the timely placement, repair, and revision of vascular accesses for patients with ESRD. The second such comment had concerns with RVUs in the PFS and suggested the Innovation Center has authority to supplement, beyond the PFS, payments to surgeons that increase access to and availability of procedures that are gateways.
Another such comment urged the Innovation Center to address PD
catheter placement and consider possible alternate payment structures such as retroactive payment for successful placement of PD catheters that are proven to have been successful over time or establishment of a bonus structure similar to the Kidney Transplant Bonus under the KCC
Model; the commenter also suggested that such innovations should include pediatric patients. The same commenter also urged CMS to not exclude pediatric patients from innovative policies to promote PD catheter placement.
Response: We plan to continue working with other agencies and stakeholders to coordinate and to inform our decisions regarding the potential for incorporating peritoneal dialysis into the ETC Model and any related quality measurement and reporting requirements. While we stated that we would not be responding to specific comments submitted in response to this RFI in the CY 2022 ESRD PPS final rule, we will actively consider all input as we continue testing the ETC Model. Any updates to specific program requirements related to peritoneal dialysis and quality measurement and reporting provisions would be addressed through separate and future notice-and-comment rulemaking, as necessary.
2. Beneficiary Experience Measure Request for Information While a beneficiary experience measure is not currently included in the ETC Model, in the CY 2022 ESRD PPS
proposed rule 86 FR 36396, we sought comment on the inclusion of a measure to capture the beneficiary experience of home dialysis care. We invited public comment on any aspect of a patient experience measure. We noted that questions to consider include the following:

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a. What domains of a patient experience of care with home dialysis would be the most useful to assess and why?
b. Would you prefer the measure to be newly developed or an update to an existing measure? If an update, which existing measure should be updated?
c. How would a patient experience measure be best used to further the purpose of the ETC Model?
d. How should CMS use a patient experience measure to assess the quality of care of beneficiaries?
e. How should CMS use a patient experience measure to incentivize improved quality of care in the ETC
Model and/or for other CMS programs?
CMS also considered publishing the quality outcomes for the ETC Model. We invited public comment on any aspect of reporting quality data, and specifically sought input on the following:
f. What is the frequency with which CMS should disseminate the results?
g. What should be the unit of analysis for the reporting data?
For the complete discussion of this RFI, see the CY 2022 ESRD PPS
proposed rule, 86 FR 39396.
Comments: Commenters were appreciative that CMS solicited feedback and there was overwhelming support for inclusion of a measure assessing beneficiary experience on home dialysis in the ETC Model. In general, the commenters thought the inclusion of a measure to assess beneficiary perceptions of the care they receive would be useful to inform changes that can improve the patients health and well-being. Commenters concurred with CMS that the current ICH CAHPS is not sufficient to capture the beneficiary experience of home dialysis patients and strongly encouraged CMS to work with the kidney community to develop a useful measure that is endorsed by the National Quality Forum NQF.
A few commenters continued to recommend that CMS continue to develop and improve the ICH CAHPS, with a particular focus on adding a home dialysis survey to allow the patient experience to be compared across settings.
However, more commenters recommended that the agency not update an existing measure, such as ICH
CAHPS or the Patient Activation Measure PAM, and instead develop an entirely new instrument and include questions that are most meaningful to patients. A commenter noted that measuring the patient experience of dialysis in a home setting includes components of in-center dialysis, home
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Federal Register - November 8, 2021

TitreFederal Register

PaysÉtats-Unis

Date08/11/2021

Page count424

Edition count7801

Première édition14/03/1936

Dernière édition24/06/2026

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