Kidney Care Partners Submits Comments on Section 232 Investigation into Medical Devices
October 20, 2025
Nation’s Largest Kidney Care Coalition Urges Administration to Preserve Access to Care for Those Living with ESRD
WASHINGTON – Kidney Care Partners (KCP)—the nation’s largest non-profit, non-partisan kidney care coalition representing patients, dialysis professionals, physicians, nurses, researchers, therapeutic innovators, transplant coordinators, and manufacturers—today submitted comments to the Bureau of Industry and Security (BIS) under the U.S. Department of Commerce in response to its Section 232 investigation into personal protective equipment, medical consumables, and medical equipment, including devices.
In its comments, KCP urged the Commerce Department to exclude medical supplies related to the treatment of End-Stage Renal Disease (ESRD) from tariffs, as such measures could have grave implications for the nation’s ESRD patient population. “ESRD Medical Supplies are critical, life-saving, and necessary to the survival of Americans living with ESRD, which is a chronic, permanent condition,” KCP wrote. “Loss of access to these ESRD Medical Supplies for even a short period of time could result in severe health consequences for ESRD patients, including death.”
KCP also highlighted that dialysis providers are reimbursed through the ESRD Prospective Payment System (PPS), which provides a single adjusted payment that includes services, drugs, laboratory tests, medical equipment, and supplies. Given that these payments are adjusted annually based on the expected cost of care, the introduction of tariffs on ESRD medical supplies could severely harm dialysis providers’ ability to provide care. Without reliable access to dialysis care, patients would likely be subject to avoidable complications that require higher-cost physician services or hospitalizations.
“ESRD medical supplies are critical to provide both dialysis and treatments following a kidney transplant,” said Mahesh Krishnan, MD, MPH, MBA. “On behalf of the more than 830,000 patients living with ESRD, KCP calls on the Department of Commerce to consider the unique impact on this population when making decisions on tariffs or other trade measures.”
To read the full letter, click here.
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