On October 31, 2014, CMS issued a final CY 2015 End-Stage Renal Disease (ESRD) PPS and Durable Medical Equipment Prosthetics, Orthotics, and Supplies (DMEPOS) final rule. CMS finalized its proposal to increase overall ESRD payments by 0.3 percent, including a 0.5 percent payment increase for hospital-based ESRD facilities. The agency also adopted a two-year transition period in which it will increase the labor-related share of the ESRD PPS payment rate, softening the blow to rural ESRD facilities in low-wage areas that will experience a decrease in their ESRD payment rates. A detailed description of CMS’s calculation of the labor-related share is available in a discussion of the CY 2015 ESRD proposed rule, available here.
In addition, CMS will raise the ESRD outlier fixed-dollar loss amount for pediatric patients from $54.01 to $54.35 (down from the proposed increase of $56.30), and increase the Medicare Allowable Payment (MAP) amount from $40.49 to $43.57. For adult patients, CMS proposes to lower the fixed-dollar loss amount from $98.67 to $86.19 (up from the proposed $85.24), and increase the MAP amount from $50.25 to $51.29.
The final rule adopted a number of revisions to the PY 2017 and PY 2018 ESRD Quality Incentive Program. For PY 2017, CMS finalized the addition of eight clinical measures and three reporting measures. With respect to the clinical measures, one is new (the proposed Standardized Readmission Ratio measure), while CMS opted not to revise the National Healthcare Safety Network (NHSN) Bloodstream Infection in Hemodialysis Outpatients measure. CMS did remove as topped out the “Hemoglobin Greater than 12” measure. As for the reporting measures, CMS states that facilities will no longer be able to attest that they only had a single qualifying case to avoid being scored on the measure.
For PY 2018, CMS adopted eleven clinical measures and five reporting measures. CMS will group the clinical measures for PY 2018 into three subdomains: (i) Safety, (ii) Patient and Family Engagement/Care Coordination, and (iii) Clinical Care. Each subdomain will comprise 20 percent, 30 percent, and 50 percent, respectively, of the total Clinical Measure Domain score. Among the proposed revisions to the reporting measures in PY 2018 are three new measures: (i) Pain Assessment and Follow-Up, (ii) Clinical Depression Screening and Follow-Up, and (iii) NHSN Healthcare Personnel Influenza Vaccination.
The final rule also includes a number of proposed changes to the DMEPOS payment methodology for CY 2015. Notably, CMS will implement a new methodology for using data gathered from the DMEPOS Competitive Bidding Program (CBP) to adjust the fee schedule prices for DME in regions of the country with no CBPs. For certain areas under the CBP, CMS will phase in a system of monthly bundled payments (in replace of capped rental policies) to cover equipment costs, supplies, accessories, maintenance, and repair of certain equipment and devices furnished under the CBP.
CMS also adopted an exception to the change of ownership rules that would permit a competitive bidding contract supplier to sell a distinct company that furnishes a specific product category or competitive bidding area.
The CY 2015 final rule is available here.
Reporter, Christopher Kenny, Washington, DC, + 1 202 626 9253, ckenny@kslaw.com.
