NRAA Advocacy

November 4, 2009

Guidance for NRAA members making comments to the Centers for Medicare and Medicaid Services on the End Stage Renal Disease Prospective Payment System Proposed Rule.

The Centers for Medicare and Medicaid Services (CMS) released the long-awaited end stage renal disease (ESRD) Medicare prospective payment system (PPS) proposed rule on September 15, 2009. The proposed bundled payment system, required by the Medicare Improvements for Patients and Providers Act of 2008 (MIPPA), will replace the current payment system beginning January 1, 2011.

It is important for the NRAA membership to voice its concerns about the ESRD bundled payment system and educate CMS about the bundle’s impact on small and medium sized providers. NRAA encourages your organization or individuals within your organization to submit written comments directly to CMS by the December 16th deadline.

The following information is being made available to NRAA members to assist you in drafting comments. The information in the template comes from the most current draft of the NRAA letter to CMS. The information is accurate as of Wednesday, November 4, 2009, but is subject to change and revision. Make sure you have verified your information and the directions for submission before you submit your comments to CMS.

Below are resources to help you draft your comments. Resources include:

• Two summaries of the ESRD bundled PPS proposed rule prepared by Avalere Health
• The full text of the proposed rule
• Comment submission instructions
• Comment letter template with an outline issues of concern to small and medium dialysis organizations.

For a high-level and more detailed summary of the proposed rule prepared by Avalere Health click here, and here.

For the full text, 547 pages, of the ESRD Medicare PPS proposed rule click here.

Click here for instructions on how to submit comments to CMS.

NOTE: To submit documents electronically, click here.

• Click the “Submit a Comment” tab.
• Under “Select Document Type” select “Proposed Rule.”
• Enter “End Stage Renal Disease” as your key word and hit “Search.”

Click here for suggested points to cover in your document. The template is NOT provided as a final draft of a letter to CMS, but as a way of assisting you to writing your own letter.

NRAA would appreciate receiving a copy of your written comments. When you submit your comments, e-mail a copy to NRAA at nraa@nraa.org.

Return to Top of Page

A credible advocate and resource for all Chronic Kidney Disease (CKD) providers through legislation, regulation and education.