August 25, 2015
Andrew Slavitt
Acting Administrator
Centers for Medicare and Medicaid Services
Room 445–G
Hubert H. Humphrey Building,
200 Independence Avenue, SW
Washington, DC 20201
RE: CMS-1628-P: Medicare Program; End-Stage Renal Disease Prospective Payment
System and Quality Incentive Program
Dear Acting Administrator Slavitt:
The Renal Physicians Association (RPA) is the professional organization of nephrologists whose
goals are to ensure optimal care under the highest standards of medical practice for patients with
kidney disease and related disorders. RPA acts as the national representative for physicians
engaged in the study and management of patients with kidney disease. We are writing to address
the status of the Standardized Readmissions Ratio (SRR) Measure (#2496) as outlined in the QIP
Proposed Rule.
As the Agency knows, there have been extensive interactions over the past 18 months between
CMS, the National Quality Forum (NQF), and concerned stakeholders led by the RPA regarding
certain aspects of the proposed measure that were deemed to be less than optimal by all parties.
The result of these discussions announced in June 2015 was endorsement of the SRR measure
subject to three conditions: (1) that CMS will exclude from the SRR measure numerator and
denominator all index discharges resulting in readmissions occurring within the first three days
following discharge from the acute care hospital; (2) that CMS will work with the appellants to
identify and test additional risk adjustment factors within one year; and (3) that CMS will
identify a mechanism by which facilities can have access to more updated information on their
crude (i.e., nonadjusted) readmission rates within one year.
However, these conditions are not reflected in the measure as described in the QIP proposed rule,
and RPA believes it is of paramount importance that the measure not be used further absent the
agreed-upon conditions being met. To be clear, RPA greatly appreciates the flexibility that CMS
demonstrated in agreeing to the conditions, and while the process to reach consensus on the
issues above was lengthy, it yielded an acceptable result, making it doubly important that the
terms of the agreement be fulfilled.
As always, RPA welcomes the opportunity to work collaboratively with CMS in its efforts to
improve the quality of care provided to the nation’s kidney patients, and we stand ready as a
resource to CMS in its future endeavors. Any questions or comments regarding this
correspondence should be directed to RPA’s Director of Public Policy, Rob Blaser, at 301-4683515, or by email at rblaser@renalmd.org.
Sincerely,
Rebecca Schmidt, DO
President