Creation/Revision Date: September 19, 2012
September 10, 2012
Marilyn B. Tavenner, Acting Administrator
Centers for Medicare and Medicaid Services
Department of Health and Human Services
P.O. Box 8013
Baltimore, MD 21244-8013
Subject: Kidney Patient Access to ESRD Nutritional Therapies
Dear Acting Administrator Tavenner:
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 renal disease and related disorders. RPA acts as the national representative for physicians engaged in the study and management of patients with renal disease.
RPA is writing to express our concern regarding recent policy changes which will likely compromise the continued availability of a key nutritional drug therapy for ESRD patients -- known as intradialytic parenteral nutrition therapy (IDPN) and intraperitoneal parenteral nutrition (IPN) -- in the Medicare Part D population. It is our understanding that due to an unexpected and unpromulgated re-pricing of key components of IDPN and IPN therapies, a decrease in Medicare Part D reimbursement of approximately 80% for these services has occurred.
While use of IDPN and IPN is relatively limited, for those patients in need of these services it is essential. RPA’s nephrologist members report using IDPN and IPN in treating selected malnourished patient groups, and have attributed improvement in these patients to its application. Further, the use of these therapies is particularly important in the treatment of pediatric kidney patients, as malnourished or growing children and adolescents with obvious susceptibility to developmental issues cannot be managed with nutritional supplements alone.
While RPA recognizes that private Medicare Part D plans have the latitude to implement reimbursement changes of this nature, it is also our belief that the detrimental impact of the policy changes on this already vulnerable sub-population of kidney disease patients was unintentional. However, for now it is real and occurring, and RPA therefore urges CMS to take the administrative steps necessary to temporarily cease implementation of the policies resulting in the re-pricing of IDPN and IPN until a more knowledge-based policy development process can be pursued.
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 firstname.lastname@example.org.
Ruben L. Velez, MD
CC: Jonathan Blum, CMS Deputy Administrator
Aryana Khalid, Chief of Staff, CMS Office of the Administrator
Amy Larrick, Special Assistant, CMS Office of the Administrator