August 18, 2008
Director, Survey and Certification Group
Centers for Medicare & Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244-1850
Re: Draft Interpretive Guidance for the Survey Process of the New End Stage Renal Disease Conditions For Coverage
Dear Mr. Hamilton:
The American Nephrology Nurses Association (ANNA) is appreciative of the opportunity to comment on the Draft Interpretive Guidance for the Survey Process of the new End Stage Renal Disease (ESRD) Conditions for Coverage. ANNA is a professional nursing organization of approximately 12,000 registered nurses practicing in nephrology. ANNA members are intimately involved in the supervision and delivery of care to adults and children with kidney disease. ANNA members work in a variety of settings including dialysis facilities, transplant centers, Chronic Kidney Disease (CKD) clinics, acute care, ambulatory clinics, and long term care.
We would like to congratulate CMS on the results of their hard work and are pleased that CMS valued ANNAs input at the Community Forum last December. Our 11 members who attended the Community Forum felt that CMS was receptive to their comments and that the changes made were very positive. An example of these positive changes includes the explanations in the Governance and Quality Assessment and Performance Improvement (QAPI) sections which are clear and direct.
Upon reviewing the Draft Interpretive Guidance, we are attaching our additional suggestions and appreciate CMS considering our comments. We look forward to working with CMS in implementing the Conditions for Coverage for the effective care of our patients. If you have any questions please do not hesitate to contact me.
Sue Cary, MN, APRN, NP-C, CNN
cc: Judith Kari, National Director, CMS