DC

The Association of American Medical Colleges (AAMC) welcomes this opportunity to comment on the Centers for Medicare & Medicaid Services’ (CMS’ or the Agency’s) proposed rule entitled Medicare Program; End-Stage Renal Disease Prospective Payment system, Quality Incentive Program, and Bad Debt Reductions for all Medicare Providers 77 Fed. Reg. at 40952 (July 11, 2012). The AAMC represents nearly 300 general acute nonfederal major teaching hospitals and health systems; all 137 accredited U.S. medical schools; nearly 90 academic and scientific societies; 90,000 full time clinical faculty; and the nation’s medical students and residents. Our comments focus specifically on the end-stage renal disease (ESRD) quality incentive program (QIP). The Medicare Improvements for Patients and Providers Act (MIPPA) of 2008 required the Secretary to develop a QIP that would result in a reduction in payments to providers of ESRD services and dialysis facilities that do not meet or exceed a total quality performance score on performance standards established for specified measures. The payment reduction, up to two percent of payments, was effective starting with payments for services provided on or after January 1, 2012.