WASHINGTON – Kidney Care Partners (KCP) – the nation’s leading kidney care multi-stakeholder coalition representing patient advocates, physician organizations, health professional groups, dialysis providers, researchers, and manufacturers – issued the following comments in response to the recently released final Calendar Year 2025 End-Stage Renal Disease (ESRD) Prospective Payment System (PPS), Payment for Renal Dialysis Services Furnished to Individuals with Acute Kidney Injury (AKI), End-Stage Renal Disease Quality Incentive Program (QIP), and End-Stage Renal Disease Treatment Choices Model (ETC).

“We applaud CMS’s efforts both in recognizing that providing oral-only medications as part of the bundle requires additional funding, as well as creating access for AKI patients to home dialysis,” said Mahesh Krishnan, MD, MPH, MBA, Chair of Kidney Care Partners. “However, KCP has consistently raised concerns that significant changes are needed to the ESRD PPS system to maintain an appropriate level of care, access, and reimbursement for the more than 557,000 Americans who rely on regular dialysis treatment.”

KCP appreciates that the rule provides additional money to help dialysis providers mitigate the cost of providing oral-only phosphate binders when they are reimbursed under the Part B program. The coalition is also pleased that CMS not only extended home dialysis modalities to individuals with AKI but also removed the second budget neutrality adjustment that would result in a cut of nearly $9 per treatment for patients selecting these modalities.

Yet, while it is important to expand the outlier pool to include innovative medications, this policy modification will not address the underlying problem that the base rate is insufficient to support adding new treatment options without adding new money. Meaningful reform – such as that included in the Chronic Kidney Disease Improvement in Research and Treatment Act of 2023 (H.R. 5027/S. 4469) – is needed to provide a permanent reimbursement pathway for innovative drugs and devices.

As KCP looks to the future, it remains concerned that the bundle is increasingly not functioning as intended, as demonstrated through MedPAC’s projected margin of zero percent for FY2024 for dialysis facilities. Reform is needed to ensure that the bundle rate can be permanently adjusted when new treatment options become available, as is done in the hospital and other provider settings. As noted in KCP’s comments to the proposed rule and recognized by the preamble of the final rule, the existing market basket methodology does not accurately capture changes in cost, especially when it comes to staffing costs. Compared to other providers in Medicare, dialysis facilities have received significantly lower annual payment updates over the last several years. Failure to accurately reflect the real cost of dialysis services impacts providers’ ability to offer care and limits patient access. This also makes it extremely challenging for dialysis facilities to compete with wages offered by other providers, such as hospitals, which have seen significant increases in additional funding in recent years. Furthermore, all of these issues are exacerbated by applying a budget neutrality adjustment to the new ERSD-specific geographic wage index, which the statute does not require. This calculation reduces the update by one percent at a time when the Medicare margins are zero. 

KCP looks forward to engaging with CMS and Congress to identify and implement changes to the market basket and update its methodology to better reflect actual cost changes. These reforms are necessary to ensure patients who rely upon dialysis have access to high-quality, well-trained staff and can dialyze on a schedule that meets their work and family obligations. KCP is eager to work with Congress and CMS to address this problem and ensure that ESRD patients are not left behind.

“While the full impact of this final rule remains to be seen, KCP is already engaged with congressional champions on legislation to require the adoption of a truly sustainable reimbursement policy to support innovation,” concluded Krishnan. “We remain committed, as always, to continuing our work with Congress and the Administration to improve our nation’s system of kidney care.”