While KCP appreciates that CMS updates the payment rate in the CY 2023 ESRD PPS, it unfortunately does not address the major barriers created by the labor crisis facing the entire kidney care community.  A three percent update does not offset the more than 8 percent-plus increase in workforce costs that federal data indicate have occurred in the last year.  KCP members are disappointed that CMS did not provide an interim fix to this larger problem by adjusting the base rate to address previous inaccurate estimates in the forecast of the ESRD updates during the past several years, as KCP had requested.  It is imperative that the Medicare rates recognize the dire situation to support quality care for individuals with kidney failure who require life-sustaining dialysis treatments. We hope to work with the agency in the coming weeks to find an immediate solution to this problem.

We are pleased that CMS sought comments on removing barriers to the long-term adoption of innovative products in the proposed rule.  We understand that CMS could not finalize a policy in this rulemaking.  We strongly encourage CMS to propose a policy based on the comments it received related to an add-on for new products that would come within a functional category after their Transitional Drug Add-on Payment Adjustment (TDAPA) ends.