Here is a mini tweet thread about the RFA for the voluntary kidney disease models released by CMS yesterday. First, the due date for applications is January 22, 2020 (!). Decisions will be made and applicants informed in 'Winter' 2020, with 2020 being an implementation year. (1)
CMS will be doing all of the expected monitoring and oversight, interoperability will be required, using 2015 CEHRT, and CMS will be doing waivers for payment issues ('benefit enhancements') but not fraud and abuse issues at this time; OIG and the DOJ have to do those. (2)
The RFA outlines all of the expected requirements about participants being legal entities, applicant eligibility, beneficiary eligibility, beneficiary protections, and data sgaring (that is, CMS sharing data with participating entities). (3)
On payment, CMS is establishing a quarterly pmt for CKD pts (CKD QCP) = to the current mid-level MCP pmt (~$242), & will pay the mid-level amount for ESRD pts, regardless of the # of visits, so nephs get ~$242 quarterly for CKD pts, and the same amt monthly for ESRD pts. (4)
For CKD patients, all O/P E&M services are not separately billable, this includes CCM, TCM, ACP, AWV; however, practices will still be required to bill for these services, for data collection and quality purposes. (5)
The kidney transplant bonus is still there, $15,000 total, $2,500 in yr1, $5,000 in yr2, $7,500 in yr3, for every aligned beneficiary receiving a transplant, from either a LOD or deceased donor, w/o return to dialysis. (6)
There will be a performance based adjustment (PBA) based on quality and utilization measures, with the utilization measures aimed at incentivizing efficient appropriate health care delivery (7).
The benefit enhancements address KDE, telehealth, post-discharge home visits, home health, home health certified by NPs, and concurrent care for beneficiaries who elect hospice. (8).
The KCF model concludes with information on termination and how to submit an application, with a tempalte for applying included (9).
The CKCC portion of the RFA that establishes kidney care entities (KCEs) that require participation of a transplant provider and can include dialysis facilities, is identical to the KCF re CKD/ESRD payments, the benefit enhancements, and other issues. (10).
Differences between the KCF and the KCE models address the risk bearing options included in the KCE (graduated, professional, and global), and the extent to financial issues such as assets, risk corridors, and stoploss are addressed. (11/end).
