LA

Document ID: CMS-2012-0080-0007
Document Type: Public Submission
Agency: Centers For Medicare & Medicaid Services
Received Date: August 08 2012, at 12:00 AM Eastern Daylight Time
Date Posted: August 16 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: 810c7962
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This is comment on Proposed Rule

Medicare Program: End-Stage Renal Disease Prospective Payment System, Quality Incentive Program, and Bad Debt Reductions, etc.

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I am commenting on the proposed adjustment for PY2015 ESRD QIP, file number CMS-1352-P. Our facility generally has a patient population of high 40's to low 50's range. In 2011, only 27 or 28 of our patients were medicare primary after exclusions were taken into account. Given this number, we would have to have 100% meet URR goal to be within your expected range. With only one patient not meeting goal, 26 of 27 patients, we were 96.3%--below QIP goal. We would have to have 34 patients (33/34 = 97%) in order to meet the QIP goal with one patient out of range. We feel an adjustment should be made to the calculation, because with an aging patient population and multiple medical comorbidities it is very difficult, if not impossible, to maintain 100% in range every year.