Statement by Kidney Care Partners on The ESRD Treatment Choices (ETC) Model

September 18, 2020

Kidney Care Partners (KCP) is carefully reviewing the release of the ESRD Treatment Choices Model today as a final rule, and we will provide a more detailed response following that review process.

KCP thanks the Administration for its continued efforts to improve kidney care quality and care delivery to our nation’s most vulnerable Medicare population – those individuals living with kidney failure who rely on dialysis care or kidney transplants.

The Administration’s efforts to improve patient access and choice, namely encouraging use of home dialysis and access to – and better coordination of – available organs for transplants, has long been a top priority of the kidney community. Incentivizing living kidney donors by providing financial support for recovery time, childcare and eldercare expenses is critical to improve the pool of available organs for transplant, which are in very short supply in this country for the 100,000 individuals on the transplant waiting lists.

While we appreciate the decision to reduce the scope of the model from the proposed 50 percent to 30 percent, we remain concerned over fears voiced by patient organizations and providers about patients who do not select home dialysis being disadvantaged by the Model have not been addressed in a way to allay their anxieties. While the Model would expand the Kidney Disease Education benefit, we know that early education before patients enter the dialysis facilities is essential to helping patients understand and adopt home dialysis modalities.  Yet, the waivers provided do not include dialysis facilities and their multi-disciplinary care teams, which is something that Members of Congress have specifically sought to do in The Chronic Kidney Disease Improvement in Research & Treatment Act.

It remains critical that the patient and physician voice be in the forefront regarding access and choice for care settings – such as home care – that are most desirable and appropriate for the patient given the healthcare needs and associated co-morbidities, their home support and the home environment itself.

KCP looks forward to our continued constructive and productive collaboration with our nation’s policymakers on our mutual goals of sustained quality improvement, protecting the integrity of the Medicare ESRD, and patient access and choice to quality kidney care.