The NRAA commissioned a research firm, Dobson | DaVanzo & Associates, to examine the accuracy of Medicare End Stage Renal Disease Prospective Payment System (ESRD PPS) rate setting as influenced by dialysis provider Medicare Cost Reports (MCRs).
- We evaluated how MCR data affects payment rates for dialysis services and propose cost report instruction and content changes to CMS as warranted.
- Identify areas where costs are reported inconsistently
- Identify patterns of costs which may differentiate sections of the industry
- Identify potential flaws in the payment system rooted in cost report data
- Conducted a literature review to determine key analytic variables as used in the PPS and policy context
- Sources include University of Michigan Kidney Epidemiology and Cost Center reports on the initial design and 2016 refinements of the ESRD PPS, Medicare Payment Advisory Commission (MedPAC) reports to Congress, recent proposed and final rules of the ESRD PPS published by CMS, and key responses to public rulemaking comment periods.
- Conducted quantitative analyses of 2016 MCR data pertaining to key variables as applied in payment system rate setting.
- Convened a Technical Expert Panel (TEP) of representative of NRAA membership with significant and diverse expertise in cost-reporting and dialysis payment to provide input on ongoing quantitative analyses as well as add context to findings and interpretation.
- The TEP included thirteen industry experts and stakeholders representing free-standing independent facilities, small-to-medium sized chains, hospital-based facilities, and private MCR contractors.
NRAA has published the full report in December 2018, and is available for download here