NY

A comment regarding the ESRD QIP, CMS-3206-P. Home dialysis is discussed, and reimbursement for greater than 3 hemodialysis treatments per week may be justified and reimbursed. However, historically, these rules were simiilar, but in actuality some FI's reimbursed for greater than 3 HD treatments per week and others did not. The number of treatments paid per week varied from 3 to at least 5, depending on where the facility is located and the assigned FI. I believe all FI's should pay according to the rule and with the same information required to justify the additional treatments. It is unfair for some facilities to receive this reimbursement while others do not. Also, it can be seen from cost reports that peritoneal dialysis, both CAPD and CCPD, have historically had greater profit margins than hemodialysis. It seems to me that now is the time to correct this and make all forms of dialysis treatment equally compensated - not in dollar amount but in profitability. Some facilities will be positioned to take advantage of the additional profit margin while others will not. Small independent facilities that get their patient referrals from hospitals that have their own chronic ESRD programs will never have home patients referred to them by these hospital programs, thus putting them at a disadvantage. Also, because of the profit margin, patients that are not necessarily good candidates to do well on PD may be encouraged to go into these programs. It may be worthwhile to look at the number of patients that go into these programs and then change to another modality within a given period of time. That would indicate a possible problem with referrals.