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RPA Comments on 2016 ESRD QIP Proposed Rule

Creation/Revision Date: August 25, 2015


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August 25, 2015 

Andrew Slavitt 
Acting Administrator 
Centers for Medicare and Medicaid Services 
Room 445–G 
Hubert H. Humphrey Building, 
200 Independence Avenue, SW 
Washington, DC 20201 

RE: CMS-1628-P: Medicare Program; End-Stage Renal Disease Prospective Payment System and Quality Incentive Program 

Dear Acting Administrator Slavitt: 

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 address the status of the Standardized Readmissions Ratio (SRR) Measure (#2496) as outlined in the QIP Proposed Rule. 

As the Agency knows, there have been extensive interactions over the past 18 months between CMS, the National Quality Forum (NQF), and concerned stakeholders led by the RPA regarding certain aspects of the proposed measure that were deemed to be less than optimal by all parties. The result of these discussions announced in June 2015 was endorsement of the SRR measure subject to three conditions: (1) that CMS will exclude from the SRR measure numerator and denominator all index discharges resulting in readmissions occurring within the first three days following discharge from the acute care hospital; (2) that CMS will work with the appellants to identify and test additional risk adjustment factors within one year; and (3) that CMS will identify a mechanism by which facilities can have access to more updated information on their crude (i.e., nonadjusted) readmission rates within one year. 

However, these conditions are not reflected in the measure as described in the QIP proposed rule, and RPA believes it is of paramount importance that the measure not be used further absent the agreed-upon conditions being met. To be clear, RPA greatly appreciates the flexibility that CMS demonstrated in agreeing to the conditions, and while the process to reach consensus on the issues above was lengthy, it yielded an acceptable result, making it doubly important that the terms of the agreement be fulfilled. 

As always, RPA welcomes the opportunity to work collaboratively with CMS in its efforts to improve the quality of care provided to the nation’s kidney patients, and we stand ready as a resource to CMS in its 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


Rebecca Schmidt DO signature

Rebecca Schmidt, DO 

Renal Physicians Association

1700 Rockville Pike
Suite 220
Rockville, MD 20852

Phone: 301-468-3515
Fax: 301-468-3511

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