ANNA responds to National Quality Forum National Voluntary Consensus Standards for ESRD Care

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February 26, 2008

Rita Munley Gallagher, PhD, RN
Senior Policy Fellow
Department of Nursing Practice and Policy
American Nurses Association
8515 Georgia Avenue, Suite 400
Silver Spring, MD 20910-3492

Dear Rita:

On behalf of the American Nephrology Nurses’ Association (ANNA), I am writing to express our appreciation to you for inviting us to comment on the National Quality Forum (NQF) Review of Voting Draft Report National Voluntary Consensus Standards for End Stage Renal Disease Care - Second Round. As an organization dedicated to providing the highest quality care for individuals suffering from kidney disease, we are pleased that the NQF continues to improve the proposed ESRD measure set and research recommendations.

ANNA appreciates the work of the National Quality Forum and their tireless commitment to quality. As most are aware, nephrology nurses are painstakingly involved in establishing and tracking quality measures within ESRD programs throughout the country. We believe passionately in endorsing measures that offer clear patient care advantages. This past year has been marked by significant changes in regards to the treatment and management of anemia. In the past, hemoglobin (Hgb) measures have been achievable and relatively easily maintained. However, following the FDA's boxed warnings, ESA use has markedly decreased. It is our belief that anemia management requires individualization and that the patient's perception of their well-being or quality of life (QOL) should always be a consideration. The risks associated with ESA utilization in the ESRD population clearly warrants more investigation so that patients do not falsely suffer from a low Hgb and reduced quality of life with sub-therapeutic Hgb levels. Therefore, the American Nephrology Nurses' Association believes that it is worthwhile to track
those patients that do not achieve therapeutic targets and would support this measurement submission for endorsement.

The Patient Survival Classification based upon the standardized mortality ratio measure is not a measure that the American Nephrology Nurses' Association would support given the potential for statistical error. Drawing conclusions about quality from this type of inference has inherent flaws and would not be a measure that nephrology nurses would support.

The American Nephrology Nurses' Association appreciates the opportunity to comment on these measures. We are in hopes that our insight will be echoed by others passionate about delivering the best quality of care possible to all individuals with kidney disease.

Sincerely,

Sandy Bodin, MA, RN, CNN
President