The Academy submitted comments to the Centers for Medicaid and Medicare Services (CMS) on a proposed rule on the Medicare End Stage Renal Disease (ESRD) Prospective Payment System. There are several proposed provisions which the Academy strongly agrees with, including:
- Finalizing the Phosphate Binder Bundle
- Instituting a Major Boost for Home & Self-Dialysis Training
- Proposing Technical Adjustments to the TDAPA
- Replacing the Hypercalcemia Reporting Measure with the Facility-Level Percentage of Chronic Hyperphosphatemia in Dialysis Patients (Hyperphosphatemia) Clinical Measure
- Expanding the Low-Volume Payment Adjustment (LVPA)
If implemented, these provisions would result in increased demand for RDNs – and would have very positive results for our patients and the profession. We also propose a Malnutrition Care Score (MCS) measure for inclusion in the ESRD Quality Improvement Program (QIP). The MCS is now required in hospital settings after years of advocacy.
Further, we recommend that a staffing ratio for RDs in dialysis clinics be implemented by CMS. The National Kidney Foundation's Kidney Disease Outcomes Quality Initiative (KDOQI) has long maintained that 1:100 RDN to patient staffing ratio in dialysis clinics is the baseline requirement to effectively deliver medical nutrition therapy (MNT).
It is the gold standard, and we recommended it be adopted by CMS. The National Kidney Foundation has joined us in recommending this staffing ratio to CMS.
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