My name is Paul T. Conway and I serve as a Board Member for the American Association of Kidney Patients. As a patient who was diagnosed nearly 30 years ago, I have made the personal journey through end-stage renal disease, ESA therapy, peritoneal dialysis, organ transplantation and ongoing immunosuppression and disease management. I appear here today based on the strength drawn from my faith, the support of my wife, the deep concern and intense loyalty of those closest to me, principled employers – and one very special and selfless soul who made the decision to give me the gift of life. My presence before you is also evidence of the selflessness and skills of countless nurses, doctors and medical specialists who represent the world class American health care system. To honor my blessing of life and good health, I have had the rare privilege to give back to my country through a career in public service – service marked by positions under four presidents, including both the former and current presidents, and two governors. Today, I am here to speak with you because AAKP believes this is a critical time for patients and their health care team, and the future holds both great promise and some risk.
AAKP’s main focus for the past 40 years has been to ensure quality of care and access for all dialysis patients and potential dialysis patients. We thank you for holding this Town Hall Meeting and providing a venue for the kidney community to share our thoughts. Our nation has the unique opportunity to provide better outcomes for kidney patients – and this can lead to substantial cost savings because better outcomes translate into less reliance on the drugs, dialysis and hospitalization currently covered by Medicare.
AAKP recognizes the detailed work that went into devising the ESRD Bundled Payment System Proposed Rule. Thank you for considering the future needs of patients and recognizing the value of preserving the patient and physician relationship. Retaining the per-treatment payment schedule and payment for up to three treatments per week, unless medically necessity justified more than three weekly treatments, demonstrates forward-thinking planning for treatment advancements. This also confirms AAKP’s belief in the time-honored principle that a physician and patient must be permitted to decide a care plan best suited for that patient because medicine is fundamentally about the treatment of a unique individual.
AAKP has supported the effort to shift Medicare payment systems to increasingly focus on high-value care. But, we are concerned that without thoughtful implementation and appropriate oversight, these changes may increase barriers to care for individuals with kidney disease. We are concerned that this new bundled payment could limit access to care for patients who might inadvertently decrease the bundled reimbursement.
A patient who medically requires more previously unbundled biologicals, drugs and/or diagnostic studies may not be accepted for treatment in facilities trying to maximize their margin. This scenario could potentially hold true for patients who have been labeled as “nonadherent to medical advice” or “having a disagreeable temperament.” Any system that links financial incentives or financial disincentives with limiting access to health care for certain types of patients is easily abused by cherry picking and requires meticulous validation of self reported performance measures.
There is also concern regarding the potential to underutilize bundled biologicals, drugs and/or diagnostic studies thereby compromising patient safety and outcomes. If the Bundled Payment System goes forward as outlined, we ask for a system that uses quality indicators to objectively validate care and identify issues that need to be addressed and fixed in a timely manner.
ESRD health care has changed significantly since the initiation of the Medicare ESRD Program. We have witnessed many treatment modality and medication advances in ESRD care. It is essential that all patients have equal access to the best treatment available. Patients should not be placed in a predicament where they are directed to use a lower-grade drug or biological. AAKP urges CMS to compensate fairly for all components within the bundle and initiate appropriate controls to guarantee these issues are addressed and minimized to ensure equal patient access to high-quality care.
In the essence of time, AAKP provides the following comments and will offer details in our written comments:
- AAKP supports the development of mutually agreeable economic arrangements between payors and providers for all medically approved therapies thereby providing fair and equal access for all patients.
- AAKP expresses concern regarding the case mix adjustment for vintage on dialysis potentially limiting patients’ access to home treatment, including dialysis and transplantation.
- AAKP is apprehensive regarding potential financial disincentives for home dialysis.
- We encourage the development of quality measures to ensure URR does not penalize patients using more frequent dialysis.
- AAKP suggests that patient satisfaction and quality of life is included in the total performance score that will determine the 2% performance incentive.
We applaud your direction over the years on these issues so important to kidney patients. Our government can vastly improve the quality of care for kidney patients while saving money in many areas. Thank you for having AAKP here to speak today and we offer ourselves as a resource to you for further information.
About AAKP
AAKP is the voluntary, patient organization, which for 40 years has been dedicated to improving the lives of fellow kidney patients and their families by helping them deal with the physical, emotional and social impact of kidney disease. The programs offered by AAKP inform and inspire patients and their families to better understand their condition, adjust more readily to their circumstances and assume more normal, productive lives in their communities.
AAKP comment delivered by Paul Conway, AAKP Board Member, on Friday, Oct. 23, 2009 at the Town Hall Meeting at CMS headquarters in Baltimore, MD. Additional information about the topic of prospective payment system (PPS) is available in the Advocacy and Public Policy section of this Web site.
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