May 5, 2005
Mark B. McClellan, MD, PhD
Centers for Medicare and Medicaid Services
U. S. Department of Health and Human Services
P. O. Box 8014
Baltimore, MD 21244-8014
Dear Dr. McClellan:
The American Nephrology Nurses’ Association (ANNA) is writing to reiterate our concerns about the draft Hematocrit Measurement Audit Program Memorandum (HMA PM). As CMS moves forward to implement this policy, we urge you to consider its potential effect on the well-being and quality of life of end stage renal disease (ESRD) patients.
Many ESRD patients report dramatic changes in their functional status depending on their hemoglobin levels. An overly restrictive EPO monitoring policy could have devastating effects on this fragile patient population.
ANNA hopes you will consider the recommendations from the nephrology community in its letter of January 28, 2005 to Dr. Tunis, specifically:
- CMS should maintain only a post-payment review framework.
- The threshold for review should be Hb > 13g/Dl.
- Full and timely reimbursement of EPO claims should be made when either a) EPO dose is appropriately adjusted or, b) a higher hemoglobin level is medically justified.
- When necessary, reimbursement reductions should be based on recommended dose adjustments rather than dose edits, which do not take patient variability into account.
- Clinicians who document efforts to provide sound medical therapy should be reimbursed.
Anemia is one of the most debilitating co-morbidities of ESRD. ANNA supports a HMA, if necessary, that provides for maximum flexibility of dosing based on patient needs and physician judgment.
Suzann VanBuskirk, BSN, RN, CNN
cc: Board of Directors