Nation’s Kidney Care Community Applauds Congress’ Efforts to Implement Forecast Error Adjustment

May 22, 2023

Urges OMB and CMS to Include “Long Overdue” Adjustment in 2024 ESRD PPS Rule

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 – today applauded letters led by  Senators Ben Cardin (D-MD) and Marsha Blackburn (R-TN) and Representatives Mike Kelly (R-PA) and Terri Sewell (D-AL) asking the Office of Management of Budget (OMB) to protect access to quality dialysis services for patients living with end-stage renal disease (ESRD) by addressing payment unpredictability in the ESRD Prospective Payment System (ESRD PPS).

The bipartisan, bicameral letters, addressed to Shalanda Young, Director of the OMB, were signed by 18 senators and 33 representatives. The correspondence notes that while “dialysis providers have dedicated even greater resources toward wages, benefits, and training,” tight labor markets and a persistent workforce shortage continue to impact providers’ ability to hire and retain caregivers with necessary dialysis expertise. They conclude with a request that the OMB and Centers for Medicare & Medicaid Services (CMS) include a forecast adjustment framework in the Calendar Year (CY) 2024 ESRD PPS.

Current payment methodology, which uses historical data to forecast an annual payment update, can produce significant forecast errors in times of economic uncertainty, as was the case in 2021 and 2022. Given that Medicare covers the majority of dialysis patients, forecast errors present unique financial challenges for dialysis providers. In March, for example, MedPAC projected a negative aggregate Medicare margin for the sector. The concern is that without a forecast correction, these ESRD PPS underpayments will continue to compound, further straining dialysis providers’ ability to deliver high-quality care while the community is already facing a workforce crisis – which directly impacts quality of care and threatens access to dialysis facilities.

To mitigate these gaps, Kidney Care Partners echoes these legislators and strongly encourages OMB and CMS to adopt a clear and consistent framework for forecast error adjustments in the CY 2024 ESRD PPS. CMS has long applied this type of methodology to the skilled nursing facility (SNF) PPS and the capital update framework under the hospital inpatient prospective payment system (IPPS).

“After two consecutive years of errors in the ESRD PPS, a forecast error adjustment is long overdue,” said Colin Roskey, Executive Director of KCP. “As a community, we applaud Senators Cardin and Blackburn as well as Representatives Kelly and Sewell for their leadership on this issue and look forward to working with CMS and OMB to implement a clear and consistent framework that ensures dialysis providers can continue to provide sustainable, high-quality care for every American living with kidney disease and kidney failure.”