HDU Comments to CMS on Dialysis in the LTC Setting

September 15, 2015

 

Mr. Andrew Slavitt

Acting Administrator

Centers for Medicare & Medicaid Services

Department of Health & Human Services

Attention: CMS-3260-P

P.O. Box 8010

Baltimore, Maryland 21244

Re: CMS-3260-P: Medicare and Medicaid Programs; Reform of Requirements for Long-Term Care Facilities

Dear Acting Administrator Slavitt:

Home Dialyzors United (HDU) appreciates the opportunity to provide the Centers for Medicare & Medicaid Services (CMS) with comments on its Proposed Rule updating the requirements which Long-Term Care (LTC) facilities must meet to participate in the Medicare and Medicaid programs.

HDU, a 501(c)(3) non-profit organization, is the only dialysis patient group dedicated to home dialysis.  Our mission is to inspire, inform, and advocate for an extraordinary quality of life for the home dialyzor community.  We know from personal experience that, with the right dialysis treatment, patients with ESRD (and their families and care partners) can lead a normal life, enjoying family and friends, and pursuing employment, education, volunteer, and leisure activities.  We also know that studies have repeatedly shown that patients who dialyze at home have better treatment outcomes.

Home dialysis, which includes peritoneal dialysis (PD) and home hemodialysis (HHD), is a treatment option that offers patients a better quality of life in both physical and psychosocial areas.  Patients and their families are better able to pursue their individual life goals. Currently, about 10 percent of U.S. dialysis patients receive treatment at home.  However, HDU believes that many more patients could benefit from home dialysis.  That includes those patients who are in LTC facilities.  We further believe that dialysis providers, health professionals, and policymakers all play a vital role in ensuring that patients have access to the modality of their choice.

HDU applauds CMS for including in the Proposed Rule the importance of individualized, high-quality dialysis services to end-stage renal disease (ESRD) patients admitted to nursing facilities and the importance of patient preferences regarding their care.

HDU concurs with the Alliance for Home Dialysis whose comments include the following:

“The Alliance supports the proposed regulations at §§ 483.11(b) and 483.25(d)(14), which is supportive of patients who may choose to continue on the same home dialysis modalities after entering a nursing home facility.  The regulations at proposed § 483.11(b) provide that a facility’s responsibilities include ensuring that the resident is “informed of, and participates in, his or her treatment to the extent practicable . . . and that the resident participates in care planning, making informed decisions, and self-administering drugs when appropriate.”  Although the regulation itself does not specifically mention dialysis, CMS notes in the preamble that “[i]n addition to the self-administration of drugs, residents may also self-administer or take part in other health care practices, such as dialysis.”  Similarly, we are pleased to see the proposed regulation at § 483.25(d)(14) – concerning quality of care and quality of life – which requires the facility to ‘ensure that residents who require dialysis receive those services in accordance with professional standards of practice and the residents’ choices.’ ” 

Unfortunately, HDU is aware of several of its members who entered nursing facilities for short term rehabilitation for conditions other than chronic kidney failure and were denied the opportunity to continue with their previous home dialysis modality, despite the fact that the treatment was appropriate and approved by their physician. As a result, those persons suffered dramatic setbacks in their overall health, or even died.

Therefore, HDU is pleased that CMS emphasizes the importance of nursing facilities recognizing each resident’s individuality and supporting resident’s unique goals for “attaining or maintaining their highest practicable physical, mental, and psychosocial well-being.”  For patients admitted to LTC facilities who are already utilizing dialysis, either at home or in-center, allowing these patients to continue with the same modality is vital to their well-being.  Continuity of care is maintained and the patient’s individuality and preferences are recognized.  As long as the nephrologist determines the modality is appropriate, self-management should be encouraged.

In addition, HDU encourages the agency to include in its Final Rule the changes proposed via the newly-created § 483.21(c) on discharge planning.  This section, which better aligns LTC and hospitals would ensure that ESRD patients receive a comprehensive assessment before they leave LTC facilities, and that patients and family receive guidance on post-discharge care and their treatment options.  Collaboration and meaningful communication among all members of the health team is vital to ensuring better outcomes.

HDU is a charter member of the Alliance for Home Dialysis and strongly agree with that organization’s submission on the proposed rules:

“To further strengthen patient protections and prevent avoidable hospital admissions, the Alliance urges CMS to include in § 483.21(c) a requirement that, as part of a patient’s discharge, the LTC facility share relevant health status information with the dialysis facility overseeing his or her care, whether at home or in-center.  We would encourage CMS to include within this subsection a provision addressing timeliness to ensure that information is shared with facilities upon discharge and before the patient begins (or re-commences) his or her treatment with the facility.  Timely communication of discharge information between providers is critical to ESRD patients during a care transition to prevent adverse medical events.”

HDU would also encourage CMS to include a minimum education requirement for LTC staff.  This in-service education should cover not only the basic information about ESRD and dialysis, but also the nursing implications of caring for these patients on a day to day basis.  This requirement would ensure the health and safety of ESRD patients and help in reducing re-hospitalizations.  Presently, 33% of hemodialysis patients are re-hospitalized within 30 days of discharge as opposed to 17.45% of the general Medicare population.  Despite this, many RNs and CNAs state that they are totally uneducated or woefully undereducated about caring for ESRD patients.  This education requirement should not be so burdensome that LTC facilities refuse to accept patients on dialysis.

As President of the HDU Board of Directors, and a former licensed long term care administrator, I speak for the entire board in expressing our appreciation to CMS for the opportunity to provide comments on the proposed updates to the LTC facility Conditions for Participation.  We look forward to working with CMS in the future to advance policies that support the well-being and quality of life of all dialysis patients, and especially those who undertake home dialysis.  Please do not hesitate to contact us if you have any questions.

Best regards,

 

Denise Eilers, BSN, RN (and former HHD care partner)

President

Home Dialyzors United

 

 

 

 

 

 

 

 

September 15, 2015

 

Mr. Andrew Slavitt

Acting Administrator

Centers for Medicare & Medicaid Services

Department of Health & Human Services

Attention: CMS-3260-P

P.O. Box 8010

Baltimore, Maryland 21244

 

Re: CMS-3260-P: Medicare and Medicaid Programs; Reform of Requirements for Long-Term Care Facilities

 

Dear Acting Administrator Slavitt:

 

Home Dialyzors United (HDU) appreciates the opportunity to provide the Centers for Medicare & Medicaid Services (CMS) with comments on its Proposed Rule updating the requirements which Long-Term Care (LTC) facilities must meet to participate in the Medicare and Medicaid programs.

 

HDU, a 501(c)(3) non-profit organization, is the only dialysis patient group dedicated to home dialysis.  Our mission is to inspire, inform, and advocate for an extraordinary quality of life for the home dialyzor community.  We know from personal experience that, with the right dialysis treatment, patients with ESRD (and their families and care partners) can lead a normal life, enjoying family and friends, and pursuing employment, education, volunteer, and leisure activities.  We also know that studies have repeatedly shown that patients who dialyze at home have better treatment outcomes.

 

Home dialysis, which includes peritoneal dialysis (PD) and home hemodialysis (HHD), is a treatment option that offers patients a better quality of life in both physical and psychosocial areas.  Patients and their families are better able to pursue their individual life goals. Currently, about 10 percent of U.S. dialysis patients receive treatment at home.  However, HDU believes that many more patients could benefit from home dialysis.  That includes those patients who are in LTC facilities.  We further believe that dialysis providers, health professionals, and policymakers all play a vital role in ensuring that patients have access to the modality of their choice.

 

HDU applauds CMS for including in the Proposed Rule the importance of individualized, high-quality dialysis services to end-stage renal disease (ESRD) patients admitted to nursing facilities and the importance of patient preferences regarding their care.

 

HDU concurs with the Alliance for Home Dialysis whose comments include the following:

“The Alliance supports the proposed regulations at §§ 483.11(b) and 483.25(d)(14), which is supportive of patients who may choose to continue on the same home dialysis modalities after entering a nursing home facility.  The regulations at proposed § 483.11(b) provide that a facility’s responsibilities include ensuring that the resident is “informed of, and participates in, his or her treatment to the extent practicable . . . and that the resident participates in care planning, making informed decisions, and self-administering drugs when appropriate.”  Although the regulation itself does not specifically mention dialysis, CMS notes in the preamble that “[i]n addition to the self-administration of drugs, residents may also self-administer or take part in other health care practices, such as dialysis.”  Similarly, we are pleased to see the proposed regulation at § 483.25(d)(14) – concerning quality of care and quality of life – which requires the facility to ‘ensure that residents who require dialysis receive those services in accordance with professional standards of practice and the residents’ choices.’ ” 

Unfortunately, HDU is aware of several of its members who entered nursing facilities for short term rehabilitation for conditions other than chronic kidney failure and were denied the opportunity to continue with their previous home dialysis modality, despite the fact that the treatment was appropriate and approved by their physician. As a result, those persons suffered dramatic setbacks in their overall health, or even died.

Therefore, HDU is pleased that CMS emphasizes the importance of nursing facilities recognizing each resident’s individuality and supporting resident’s unique goals for “attaining or maintaining their highest practicable physical, mental, and psychosocial well-being.”  For patients admitted to LTC facilities who are already utilizing dialysis, either at home or in-center, allowing these patients to continue with the same modality is vital to their well-being.  Continuity of care is maintained and the patient’s individuality and preferences are recognized.  As long as the nephrologist determines the modality is appropriate, self-management should be encouraged.

In addition, HDU encourages the agency to include in its Final Rule the changes proposed via the newly-created § 483.21(c) on discharge planning.  This section, which better aligns LTC and hospitals would ensure that ESRD patients receive a comprehensive assessment before they leave LTC facilities, and that patients and family receive guidance on post-discharge care and their treatment options.  Collaboration and meaningful communication among all members of the health team is vital to ensuring better outcomes.

 

HDU is a charter member of the Alliance for Home Dialysis and strongly agree with that organization’s submission on the proposed rules:

 

“To further strengthen patient protections and prevent avoidable hospital admissions, the Alliance urges CMS to include in § 483.21(c) a requirement that, as part of a patient’s discharge, the LTC facility share relevant health status information with the dialysis facility overseeing his or her care, whether at home or in-center.  We would encourage CMS to include within this subsection a provision addressing timeliness to ensure that information is shared with facilities upon discharge and before the patient begins (or re-commences) his or her treatment with the facility.  Timely communication of discharge information between providers is critical to ESRD patients during a care transition to prevent adverse medical events.”

 

HDU would also encourage CMS to include a minimum education requirement for LTC staff.  This in-service education should cover not only the basic information about ESRD and dialysis, but also the nursing implications of caring for these patients on a day to day basis.  This requirement would ensure the health and safety of ESRD patients and help in reducing re-hospitalizations.  Presently, 33% of hemodialysis patients are re-hospitalized within 30 days of discharge as opposed to 17.45% of the general Medicare population.  Despite this, many RNs and CNAs state that they are totally uneducated or woefully undereducated about caring for ESRD patients.  This education requirement should not be so burdensome that LTC facilities refuse to accept patients on dialysis.

 

As President of the HDU Board of Directors, and a former licensed long term care administrator, I speak for the entire board in expressing our appreciation to CMS for the opportunity to provide comments on the proposed updates to the LTC facility Conditions for Participation.  We look forward to working with CMS in the future to advance policies that support the well-being and quality of life of all dialysis patients, and especially those who undertake home dialysis.  Please do not hesitate to contact us if you have any questions.

 

Best regards,

 

Denise Eilers

 

Denise Eilers, BSN, RN (and former HHD care partner)

President

Home Dialyzors United