MA

Of the two anemia management measures chosen, the low hemoglobin measure (ie % of patients with hemoglobin <10) is proposed at being unfairly weighted 2x greater than adequacy or high hemoglobins. Furhtermore, achieving 2% or less which is the proposed standard will be extrememly difficult for many units and likely lead to overuse of ESAs to avoid the low hemoglobins (and to avoid losing 1% of Medicare $$). This goes against recent FDA warnings against pushing too much ESA to achieve high hemoglobins. The 2008 data that is being used was prior to recent studies and FDA warnings, and at that time Providers were unaware of danger of high hemoglobins. Now that we are all aware, it would seem much more fair and safe for patients to have a more balenced standard of 10% of pts with hemoglobins <10, and 10%>12 (or 15%). In terms of URR, it should be switched to Kt/V in future, and would follow KDOQI guidelines + adjust goal for residual renal function and patients on dialysis 4x or 5x week, or it won't be accurate and will penalize units dialyzing patients more frequently than 3x week. Residual renal function is an independant predictor of mortality and needs to bne taken into account when accounting for adequacy.