The CMS ESRD proposals are important steps forward to begin to address the health and access inequities that individuals who depend on dialysis care have faced in our health care system.

KCP appreciates the ongoing flexibilities CMS has provided in the ESRD quality improvement programs (QIP) as we continue to battle the COVID 19 pandemic, which disproportionately impacts individuals with kidney disease and kidney failure. While we would like to have seen some tweaks to the ESRD PPS and the ETC model as we noted in out comment letters, we remain supportive of many of these proposals that CMS has finalized in this rule.

KCP is also pleased that CMS decided to incentivize access to nocturnal dialysis for all ESRD beneficiaries, regardless of the ownership status of the facility where they receive dialysis.