The Nonprofit Kidney Care Alliance (NKCA) is an organization representing eight nonprofit dialysis providers across the country, which collectively serve more than 22,500 patients at over 326 care sites in 32 states. Among its core goals is educating policymakers toward “efficient and effective care" for dialysis patients. The Government Relations & Public Policy group at Hooper, Lundy & Bookman recently advised NKCA in drafting comments to the Centers for Medicare & Medicaid Services (CMS) in regard to its hospice proposed rule for fiscal year 2022.
As nonprofit providers, NKCA’s dialysis centers predominantly serve Medicare and Medicare Advantage patients, who make up approximately 85% of the organization’s patient population. With the firm’s help, NKCA offered comments this June to inform CMS of the negative, albeit unintended, consequences of current hospice policy on Medicare patients with end-stage renal disease (ESRD).
Requiring patients with a principal diagnosis of ESRD to abandon dialysis in order to receive hospice services through Medicare “imposes pain and thwarts symptom management” rather than providing palliative care as intended. With palliation as the goal, NKCA has recommended an alternative policy in which:
- The patient waives their right to maintenance dialysis, in line with current policy;
- Limited dialysis episodes are covered through Medicare in accordance with a plan of care devised by the patient’s hospice interdisciplinary team, including their nephrologist; and
- Related services, such as pharmaceuticals and lab tests, would be included on a modified basis.
To avoid a “cliff” at which a patient’s care would suddenly cease, NKCA supports shorter and less frequent episodes of dialysis treatment concurrent with hospice services. This arrangement would shield Medicare patients from “significant discomfort and pain, due to shortness of breath from fluid retention, significant and discomforting itching, confusion, and nausea from uremia.”
“We are proud to represent the Nonprofit Kidney Care Alliance in pursuit of better care for patients diagnosed with ESRD. The issue of hospice policy under Medicare is one our clients care deeply about, and we are committed to helping them advocate on behalf of their patients,” says Hooper, Lundy & Bookman’s Martin Corry. The firm’s Government Relations & Public Policy team works with organizations nationwide to achieve health care reform through statutory and regulatory changes at both the federal and the state level.
Read NKCA’s full comment to CMS here.