In this letter, the Kidney Care Partners (KCP) provide CMS with comments about the Proposed Rule for Revisions to Payment Policies under the Physician Fee Schedule for Calendar Year [CY] 2006 (Proposed Rule). 70 Fed. Reg. 45764. Specifically, KCP urges CMS to:
- Adopt a drug reimbursement methodology that is sustainable and predictable, incorporates the most current pricing data available, minimizes any lag time, and recognizes the needs of smaller dialysis facilities;
- Correct the remaining errors related to the calculation of the drug add-on adjustments and comply with the congressional mandate to establish separate add-on adjustments for hospital-based providers and independent facilities;
- Implement the revised geographic wage index and provide a more appropriate transition to minimize the negative impact the revisions will have on some facilities;
- Clarify that the Agency will continue to recognize the exception status of non-pediatric facilities being paid through this process until these facilities relinquish their status in writing; and
- Include dialysis facilities as originating sites for purposes of telehealth services and implement the proposal to include medical nutritional therapy as a telehealth service.
Click here to read the complete letter [PDF file, 208K]