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RPA Letter to House Co-Sponsors of H.R. 5942, Dialysis Patient Act of 2016

Creation/Revision Date: September 15, 2016

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September 15, 2016

The Honorable Todd Young (R-IN)
U.S. House of Representatives
1007 Longworth House Office Building
Washington, DC 20515

The Honorable Earl Blumenauer (D-OR)
U.S. House of Representatives
1111 Longworth House Office Building
Washington, DC 20515

RE: H.R. 5942, Dialysis PATIENT Act of 2016


Dear Representatives Young and Blumenauer:

The Renal Physicians Association (RPA) is the professional organization of nephrologists whose goals are to ensure optimal care under the highest standards of medical practice for patients with kidney disease and related disorders. RPA acts as the national representative for physicians engaged in the study and management of patients with kidney disease. We are writing to provide RPA’s perspective on H.R. 5942, the Dialysis PATIENT Act of 2016.

RPA appreciates your leadership efforts to enhance the care provided to the nation’s kidney disease population. Further, we fully support the intent of H.R. 5942, as we believe that numerous aspects of end-stage renal disease (ESRD) care delivery in the U.S. uniquely suit the kidney patient population for integrated care models. These characteristics include: (1) a well-defined patient population; (2) frequent and coordinated interactions between patients and their nephrologists, allied health professionals, dialysis facility staff, and other providers of care; (3) the existence of substantial quality measurement and improvement activities; and (4) decades of experience in the use of alternative payment methodologies.

While RPA supports the bill conceptually, we do have several concerns about H.R. 5942 that would need to be addressed before we could endorse and/or support the bill. These are: 
 

 

 

 

Nephrologist Role in Governance—RPA strongly believes that the ESRD Integrated Care Organizations created by the bill must have legislatively-defined governance structures that require the participation of nephrologists as part of the governing board. We are concerned that the absence of nephrologists serving in prominent leadership roles in these entities will create a gap in clinical expertise and commitment in adherence to quality measures within the governing structure.

RPA recommends structuring the governing body in a manner similar to that used for the ESRD Seamless Care Organization (ESCO) model, which requires participating entities to: (1) have either a nephrologist or nephrology practice as a participant owner; and (2) maintain an identifiable governing body with ESCO participants (owners and non-owners) having at least 75% control of the ESCO’s governing body.

Incentives for Transplantation—Given that transplantation is the ideal form of renal replacement therapy, we firmly believe that it is absolutely necessary to remove any possible disincentive for transplantation, and that H.R. 5942 falls short in this regard. We recommend the required use of quality metrics to evaluate the organizations on transplant referral.

 

Transitioning of Pediatric and Young Adult Patients—RPA is concerned that the legislation does not sufficiently address the needs of pediatric and young adult ESRD patients who will transition from their pediatric care to the care provided in adult facilities operating as part of the entities created by this bill. We recommend that the bill direct the Secretary of HHS to require the organizations to work with the pediatric nephrology community to develop protocols facilitating the transition from pediatric to adult ESRD care.

 

Reference to Medical Homes—H.R. 5942 states that the organization shall integrate care and serve as the ‘medical home’ for program-eligible beneficiaries. RPA objects to the reference to ‘medical homes’ in the legislation, as that phrase has a specific meaning in a Medicare Shared Savings Program context that we believe is wholly distinct from the entities being created by the bill, and therefore call for its removal from the bill.

Again, RPA commends you and your staff for taking the lead on an issue of such critical importance to the nation’s kidney patients, and we stand ready as a resource to your offices in their future endeavors. Any questions or comments regarding this correspondence should be directed to RPA’s Director of Public Policy, Rob Blaser, at 301-468-3515, or by email at rblaser@renalmd.org.

Sincerely,
Rebecca Schmidt DO signature

Rebecca Schmidt, DO
President