Jesse Flaxenburg

Document ID: CMS-2009-0083-0014
Document Type: Public Submission
Agency: Centers For Medicare & Medicaid Services
Received Date: October 01 2009, at 11:20 AM Eastern Daylight Time
Date Posted: October 2 2009, at 12:00 AM Eastern Standard Time
Comment Start Date: September 29 2009, at 12:00 AM Eastern Standard Time
Comment Due Date: December 16 2009, at 11:59 PM Eastern Standard Time
Tracking Number: 80a3714c
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I recently learned of some of the proposed elements of the bundling package. I understand that one of the new regulations will force oral medications, including phosphate binders, sensipar and oral vitamin D analogs into the bundle. As a nephrologist, I am terrified that this will create an enormous financial disincentive to dialysis units in terms of providing these medications. This will accomplish several things. First, it will almost certainly mean that patients will end up with less of the medications which will have a direct negative consequence in terms of their health. Secondly, it will create a large amount of ill-will between dialysis providers and physicians as the former seek to minimize use of these medications while the latter seek to optimize outcomes. Nephrologists and dialysis providers need to work together for the good of the patient and this will likely make them out as adversaries. I can't imagine why CMS thinks this is a good idea. Thirdly, it will have a chilling effect on R and D for new drugs that have the potential to improve the lives of our critically ill dialysis patients. Who in their right mid would bother bringing a new and exciting drug to the market if they know CMS is going to cut them off at the knees? I beg you, please do not hang my patients out to dry. I can speak for most nephrologists in this country when I say we didn't go into this field for the money. There are far more lucrative specialties. We do this because these patients need our help. If you create regulations that prevent us from providing that help, I fear many of us will simply leave the field.

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