Letter from Kidney Care Partners (of which ANNA is a member) to the Centers for Medicare & Medicaid Services regarding CMS-1502-P: Proposed Rule for Revisions to Payment Policies under the Physician Fee Schedule for Calendar Year 2006

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]