In this letter, the Kidney Care Partners (KCP) provide the Centers for Medicare & Medicaid Services (CMS) with comments about the implementation of the EPO Monitoring Policy (EMP). The correspondences provides a critique of the dual test proposal as well as comments about the adoption of a modifier to address the greater than 500,000 units issue and excluding home dialysis from the EMP.
Click here to read the complete letter [PDF file, 192K]