U. S. dialysis providers are completing their final analyses this week as the November 1st deadline to fully opt in to the new Medicare bundling reimbursement methodology approaches. Pursuant to the new bundling rule released on July 23, 2010, providers who do not contact their Medicare fiscal intermediaries by that date to affirmatively elect to fully opt in to the bundling methodology as of January 1, 2011 will be automatically subject to the four year phase-in methodology beginning January 1, 2011.
In prior posts, I have described in more detail the conversion to the new bundling methodology, pursuant to which CMS will make a single bundled payment to the dialysis facility for each dialysis treatment that will cover all renal dialysis services and home dialysis commencing on January 1, 2011. It replaces the current system which pays facilities a composite rate for a defined set of items and services, while paying separately for drugs, laboratory tests, or other services that are not included in the composite rate.
Dialysis providers are utilizing a number of tools to determine whether to fully opt in or instead wait out the phase-in approach. These tools examine individual providers’ geography, patient mix (in terms of dialysis modality and other factors), program size, typical drug dosage statistics and other key aspects of the providers’ programs that will help providers determine the impact that bundling will have on their reimbursement. Providers that anticipate a positive impact from bundling will likely elect to fully opt in now. One such tool was developed by Jeff Lehman of Dialysis Consulting Group, Inc. and includes a six step process focusing on six separate identifying characteristics of the individual provider.
Regardless of a provider’s decision as to fully opting in or phasing in to bundling, there will surely be a renewed industry-wide focus on keeping costs low and quality high.