The National Forum for Heart Disease & Stroke Prevention submitted comments to the Centers for Medicare & Medicaid Services (CMS) regarding updates to the End-Stage Renal Disease Prospective Payment System (PPS).
The comments address potential unintended consequences of including phosphate-lowering therapies in the bundled payment system. These medications help people living with chronic kidney disease (CKD) and end-stage renal disease manage serum phosphate levels, which can affect cardiovascular health and kidney transplant outcomes.
Previous changes to the bundled payment system have created financial incentives that restricted access to certain therapies. The National Forum urged CMS to consider how current policies could disproportionately affect people with more complex health needs, including those in rural and underserved communities.
The National Forum recommends that CMS:
- Account for patients with greater health needs to avoid financial incentives that restrict access to appropriate therapies.
- Track phosphate-control outcomes for 12 months following the transition from the Transitional Drug Add-on Payment Adjustment to the base payment rate.
- Use current patient-outcome data to inform future End-Stage Renal Disease Quality Incentive Program decisions.
“CMS has the unique challenge of balancing the cost to taxpayers while also providing access to evidence-based care for both patients and providers,” National Forum executive director John M. Clymer wrote. “We urge CMS to follow the evidence and prioritize the best care for people living with CKD and ESRD.”
