NJ

Document ID: CMS-2012-0080-0005
Document Type: Public Submission
Agency: Centers For Medicare & Medicaid Services
Received Date: July 27 2012, at 12:00 AM Eastern Daylight Time
Date Posted: August 6 2012, at 12:00 AM Eastern Standard Time
Comment Start Date: July 11 2012, at 12:00 AM Eastern Standard Time
Comment Due Date: August 31 2012, at 11:59 PM Eastern Standard Time
Tracking Number: 810b3ee7
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We are a 7 station dialysis unit located on the campus of a Long Term Care Facility in N.J. (separate licenses and provider numbers). Our patient population is very unique; all with a multiplicity of commorbid entities and entering the "golden years" of their lives. We believe that we provide a very important service to this patient popluation by enhancing their continuity of care and maximization of services and quality of life (no prolonged excursions in ambulettes/ambulances etc. - not to mention the cost savings here) and maximizing physical and occupational therapies etc. We have always been proactive in ensuring compliance with the Rules and Regulations applicable to the ESRD program but now find that the new/proposed requirements will put us at a distinct disadvantage.Our patients' albumins historically are low as happens quite often with the normal aging process. The number of comorbid entities in this population exceeds the national averages and do not often count among those modifiers that enhance reimbursement. Reducing BUNs and URRs when starting points secondary to dietary intake and body mass are already on the extreme low value side to begin with is virtually impossible. Fistual First - not happening. The same disease processes that have landed them in the LTCF have affected their peripheral vasculature. Our max. census is 42 patients. If 2 or 3 of these patients do not make screen, thru circumstances beyond our control, we will be penalized economically. The math works against us. We cater to a patient popluation that larger institutions often refuse and/or may only have 1 or 2 of these patients in their 20 station plus facilities at any given time. There needs to be some consideration/relief afforded, economically, for those of us who are willing to care for this very deserving/needy popluation in the most humane manner possible. We hope that a reasonable solution can be found. Philip G. Calderone, M.D. 16 years as a practicing Nephrologist

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