ANNA submits comments to the Renal Network regarding “Delivery of Dialysis Treatment Within the Long-Term Care Facility Report”

The following comments were submitted to The Renal Network, Inc., via the online feedback form for the Special Project on the Delivery of Dialysis Treatment Within the Long-Term Care Facility.

The American Nephrology Nurses’ Association (ANNA) represents more than 12,000 registered and advanced practice nurses who care for patients with chronic kidney disease (CKD). Our members practice in a variety of roles and settings including direct care to patients on dialysis, patient education, staff training and development, and home dialysis training and support.

Thank you for allowing ANNA an opportunity to provide input into the Special Project on the Delivery of Dialysis Treatment within the Long-Term Care Facility. As the voice of nurses who care specifically for patients with CKD requiring dialysis, and as an organization, we had the project plan reviewed by our Hemodialysis, Chronic Kidney Disease, Peritoneal Dialysis and Pediatric Special Interest Groups as well as the ANNA Board of Directors. We are pleased to see the special needs of this population being addressed by The Centers for Medicare and Medicaid Services (CMS) and the Renal Network, Inc.

ANNA was pleased to have a representative on The Technical Expert Panel (TEP) that convened in Baltimore on January 20 and 21, 2006. ANNA member Susan Cronin participated on the Panel and provided recommendations on the delivery of dialysis in Long Term Care Facilities. Many of the ANNA sponsored recommendations are included in the plan. 

ANNA supports the recommendations included in the Special Project on the Delivery of Dialysis Treatment within the Long-Term Care Facility paper. In addition, we have several comments outlined below.

Staff in the LTC facilities should be adequately trained and have dedicated time for dialysis treatments. They cannot be expected to leave the dialysis treatment to care for other residents or complete other duties. Staff also needs ongoing in-services and training to maintain skills and to compensate for the high staff turnover rate in LTC facilities. CMS should assure that the knowledge base of the LTC staff is assessed, to prevent inconsistencies in procedures and inadequate technical or human support for this frequently unstable patient population.

Another recommendation ANNA would like to propose relates to the fact that many elderly patients in LTC facilities may, due to age and cardiovascular disease, have CKD stages I-IV. Patients with CKD in these stages do not require dialysis, but still have special needs. We believe these patients would also benefit from having nephrology support in the facility, especially in the areas of nutrition and social services. We believe this support could be overseen by the LTC facility with support from the nephrology team.

ANNA would like to recommend one more consideration, regarding pediatric patients who may reside in a LTC facility. We would like to see CMS and the Renal Network include language that covers this very special population. 

Thank you again for the opportunity to participate in this review.

Sincerely,

JoAnne Gilmore, BSN, RN, CNN

President

cc:  ANNA Board of Directors

      Mike Cunningham, Executive Director