2022 Policy Priorities
The scope of kidney disease is significant and goes far beyond End Stage Renal Disease (ESRD) and dialysis. KCP members are committed to meeting patients’ needs at every stage along the care continuum, and our diverse membership shares a broad vision of KCP policy priorities. These priorities range across the full spectrum of the disease cycle from education and prevention to early intervention to dialysis and, finally, to transplant and post-transplant care.
The following policy priorities focus on supporting patient choice and access in coverage options, treatment modalities, and innovative treatments and services; transforming the Medicare ESRD benefit into a more patient-centered program, advancing quality to promote transparency and patient-centered decision-making, and ensuring access to care for individuals living with kidney disease as the COVID-19 pandemic continues.
Support Patient Choice of Treatment Options
Individuals living with kidney disease, ESRD, and kidney transplants must have access to a variety of appropriate, innovative treatment modalities and coverage options, regardless of their age or location.
KCP advocates for the Centers for Medicare & Medicaid Services (CMS) to include coverage of kidney disease screening in Medicare wellness visits. By ensuring that every beneficiary has access to kidney disease screening, early detection can help patients receive vital care that could prevent worsened conditions leading to kidney failure or dialysis.
Individuals with kidney disease are disproportionately from communities of color and often experience inequities in the delivery of care, such as having greater difficulties accessing preventative care and chronic disease management services. KCP will work to identify inequities in kidney care delivery, develop recommendations to address them and tackle barriers interfering with access as patients transition to dialysis.
Additionally, KCP will support policies promoting transplants, including accessing pre-emptive transplant, expanding access to waitlists, and supporting efforts to increase the supply of organs.
With the COVID-19 pandemic still ongoing, KCP will also work toward maintaining telehealth options for individuals with kidney disease, making sure every individual can safely access care, including living donation evaluation and kidney transplant follow-up. Telehealth is an important care option for patients who may already be at a higher risk of contracting COVID-19 and other infectious diseases in hospitals and other care settings.
Further, we will support efforts to address workforce and staffing issues, including policies that provide early exposure to the nephrology field for medical students. An increase in recruitment means an increase in access to care for patients.
Expand Home Dialysis Choice
KCP supports policies that would remove barriers for individuals that seek home dialysis. To reach this goal, KCP will work to expand the Medicare Kidney Disease Education benefit and identify and seek removal of regulatory barriers to coordinating care and education between providers and facilities.
KCP is developing policies to promote and encourage innovation and eliminate barriers to the long-term adoption of innovative products and services in the ESRD Prospective Payment System (PPS) and Medicare Advantage (MA) Program. Additionally, KCP supports efforts to increase research funding through the National Institutes of Health (NIH) and KidneyX.
KCP supports policies to remove barriers to transplants, including advocating for expanding the Medicare Kidney Disease Education benefit, funding for living donor education through the HRSA annual appropriations legislation, and reduced barriers for waitlists. KCP also supports legislation and regulatory actions to increase accountability for organ procurement organizations and remove barriers for living donation, including efforts to exclude living donors from insurance coverage because of their donation.
KCP is dedicated to protecting access to care by opposing any Medicare Advantage (MA) policy that would discriminate against or provide inadequate insurance networks for individuals on dialysis.
KCP will also work to ensure that individuals with kidney disease have the same insurance options as other Americans and do not face discrimination from insurers. We will also continue to work with the kidney care community to protect charitable premium assistance.
Furthermore, KCP is working to expand access to Medigap and to extend the Medicare Secondary Payer provision options for individuals with ESRD.
Reform the Medicare ESRD Benefit
KCP is committed to reforming the Medicare End-Stage Renal Disease (ESRD) Benefit to ensure every individual with kidney care has access to high-quality care of their choice. It is time to modernize the ESRD PPS to support innovative care options, promote patient choice, and eliminate barriers to care coordination.
We will continue to seek the appropriate implementation of policies related to incorporating new products into the ESRD PPS. We are also working on identifying and pursuing the elimination of policies that create barriers to promoting high-quality care, such as inappropriate patient-level adjusters, facility adjusters, and cost-report-related policies.
KCP will work to ensure that new payment models, such as the ESRD Treatment Choices (ETC) model and the Voluntary ESRD models, effectively incentivize improvements in patients’ outcomes and avoid penalties that would undermine the delivery of high-quality care. These models should not create barriers to innovative products and services, which can lead to patients having difficulty accessing preventative and other kinds of kidney care. By including appropriate metrics and benchmarks that drive improvement, while honoring and respecting patient choice and creating accountability of all kidney care providers in influencing the adoption of home dialysis and transplant, we can ensure a modernized Medicare kidney care program that will benefit more people.
By working with organizations like MedPAC and other individuals aligned with KCP on payment issues, we can advocate for reforming the ESRD model to better serve patients. Providing opportunities for clinicians, providers, and facilities of all types, sizes, and geographic locations to participate in innovative payment models will allow us to collaboratively advocate for higher quality, more accessible care.
Additionally, KCP will work to prevent Congress from using ESRD-specific offsets for other policies, such as budget deals and entitlement reform efforts, among others, ensuring that kidney patients are put first.
Advance Kidney Care Quality
Individuals with kidney diseases are living longer and fuller lives, with more choices and better access to kidney care than ever before - but there's still more to be done.
In order to advance quality care, KCP seeks to streamline the quality programs and appropriate implementation for the Quality Incentive Program (QIP) and Five Star.
We are actively engaging with the administration to eliminate or align duplicative or inconsistent measures and structural concerns in the various ESRD-related quality programs and have Medicare programs rely upon a parsimonious set of valid, reliable measures that matter to patients and will promote quality improvement. KCP is also working to eliminate measure bloat and focus on “measures that matter.”
Quality metrics should be meaningful to patients. Therefore, KCP seeks policies that implement the intent of Congress that CMS rely upon measures endorsed by the National Quality Forum (NQF) and not use measures that the NQF has considered but not recommended for endorsement.
Additionally, KCP seeks the passage of the quality provisions in the Chronic Kidney Disease Improvement in Research and Treatment Act (S. 1971/H.R. 4065). If passed, this legislation would increase patient access to quality performance information by improving the accuracy and transparency of the ESRD quality programs by bettering patient decision making and transparency by consolidating and modernizing quality programs.
KCP will also determine ways to leverage the expertise of the Kidney Care Quality Alliance (KCQA) to develop metrics that improve outcomes, including:
- Continue efforts begun in 2021 to develop measures in the domains of transplant, home dialysis, anemia management, bone mineral, and infection control and seek their adoption in the ETC, QIP, and other ESRD quality programs, as appropriate.
- Determine appropriate level of support for KCP to assist in the testing of the Home Dialysis “CAHPS” instrument.
- Consider developing a patient-reported outcomes measure in coordination with CMS.
KCP will continue to support and advocate for policies that help to best address the COVID-19 pandemic for those living with CKD, individuals receiving dialysis treatments, and kidney transplant recipients.
By educating policymakers and Members of Congress about the impact the pandemic has had on those living with kidney disease, we can ensure that the interests of individuals with kidney disease are put first. We will also work to educate lawmakers on the healthcare workforce shortage, particularly as it relates to vaccine mandates.
KCP is working with Congress and the Biden administration to break down legislative and regulatory barriers to promote patient access to therapies available in the home setting when available during the pandemic.
Lastly, KCP will advocate for prioritizing patients on dialysis and the healthcare professionals and staff who care for them. Patients with kidney disease, especially those with ESRD, have an increased risk of developing severe cases of COVID-19. These individuals should be prioritized in receiving safe care in the home via telehealth when appropriate and having access to vaccines at dialysis centers. Kidney care providers need to have more flexibility in their approach to care during these difficult times.