ETC Model: How One Small Dialysis Organization Is Navigating Uncharted Policy Waters.

The ETC model proposes to increase access to home dialysis and transplant for patients with ESRD. Implementation of this model is happening while many dialysis organizations are still suffering the far-reaching effects of the coronavirus disease 2019 (COVID-19) pandemic. In addition, the model has the potential to negatively affect small and independent dialysis organizations disproportionately. It incentivizes home dialysis over transplant and promotes development of new home dialysis programs, rewards achievement over improvement, and places an excessive burden on small and independent dialysis organizations. Advantages of the program include the focus on self-care as an acceptable alternative to home dialysis for some patients and the potential for some organizations to make improvements in care with increased reimbursements. The authors hope that the Centers for Medicare and Medicaid Services will address many of these concerns in updated rulemaking and guidance.

Projected impact of the proposed "bundled" ESRD payment system on a small dialysis organization.

Payment for outpatient hemodialysis services is currently made by the Centers for Medicare & Medicaid Services on a per-treatment basis using a partially "bundled" composite rate adjusted for geographic and patient characteristics, plus a separately billable portion for medications and services not included in the bundle. In response to concerns over rising costs of the End-Stage Renal Disease Program, and specifically the increasing use of erythropoiesis-stimulating agents, Congress has mandated a new, more inclusive prospective payment system, in which current composite rate services, separately billable medications, and dialysis-related laboratory services will be included in a single payment. It is expected that the so-called bundle will apply a geographic wage adjuster and patient-specific case-mix factors to a base rate to calculate a per-patient, per treatment payment unit. We have modeled the proposed bundle and entered clinical and financial data for 118 Medicare patients dialyzed at a suburban dialysis center in New York State during 2006. Under the proposed bundled system, we stand to lose as much as $118,000 per year in revenue, and we find the case-mix adjusters appear to be poor predictors of our actual costs. We conclude that the proposed bundle places the small dialysis provider at significant financial risk.