Mark E. Neumann



In his message published today in Renal Watch, the weekly newsletter of the National Renal Administrators Association, president Keith Mentz summarized for administrators some of the key points in  the proposed bundled payment formula for dialysis care that was released on Sept. 15. Here are the highlighted points from his message:



    CMS interprets that they need to include all ESRD drugs and biologicals formally separately payable under Medicare Part B and Part D regardless of route of administration.  (Vaccines will continue to be excluded from the bundle).


    CMS plans to include in the bundle pay-for-service laboratory tests that are either separately billable by ESRD facilities or ordered by a physicians who is receiving monthly capitation payments (MCP) and performed by independent laboratories.


    CMS will exclude physician payments from the bundle.


    CMS proposes to continue using per treatment as the method of payment and will continue to pay up to three treatments per week unless there is medical justification for additional treatments.



    CMS proposes to eliminate Method II.


    CMS proposes to pay for all home modalities, home supplies, and home support services under the bundled system.


    CMS proposes a transition period (for switching to the bundled payment) as follows:


1.    75% of current {payment} system; 25% of bundled payment in 2011

2.    50% of current system; 50% of bundled payment in 2012

3.    25% of current system; 75%  of bundled payment in 2013

4.    100% of new bundled payment system in 2014.


    Facilities can elect to go all-in by notifying CMS 60 days prior to implementation date.


    CMS is proposing to pay a 20.2% increase to the base rate as a facility-level adjustment for low-volume facilities.


    CMS defines low-volume facility as one that performs 3,000 or fewer treatments for three consecutive years.  To qualify a low-volume facility could not have opened, closed, or have obtained a new provider number due to ownership change during the three year period.


    No provision for rural providers as CMS feels that have defined this above through the low-volume facility definition.



The NRAA will offer more analysis of the bundle at its Annual Fall Meeting in Marco Island, Florida on Oct. 7th. For more information, go to www.nraa.org.