CMS recently published the First Annual Evaluation Report (the “Report”) highlighting its most significant observations in the first year following implementation of the Kidney Care Choices Model (the “KCC Model”). By way of background, the KCC Model is a payment model which creates certain incentives for providers that are intended to improve care management for Medicare patients with chronic kidney disease (“CKD”) (Stage 4 or 5) or end-stage renal disease (“ESRD”). The KCC Model is intended to, among other things, delay the dialysis progression and increase use of home dialysis, while also aiming to reduce the cost of care and improve quality of outcomes.

Providers participating in the KCC Model engage in one of two (2) model options, including either:

1. Kidney Care First Model (the “KCF Model”): Available to nephrology practices, nephrologists, and other nephrology professionals who voluntarily elect to participate.[1] Participants receive capitated payments in return for managing the care of certain patient populations, provided that such capitation payments are subject to adjustment based on the results of quality and utilization metrics.[2] In addition, bonus payments are available for successful transplantations.[3]
2. Comprehensive Kidney Care Contract Model (“CKCC Model”): Available to nephrology practices that partner with transplant providers and certain other optional partners, such as dialysis facilities and home care providers, to form Kidney Contracting Entities (each a “KCE”).[4] The CKCC Model adopts a total cost of care approach for Medicare Parts A and B services, and is characterized by assessments of levels of risk to the individual KCEs.[5]

Participation in either the KCF Model or CKCC Model is voluntary for providers.

Key Findings

The Report identified a number of key findings for the KCC Model’s first year, including that it:

• Increased the percentage of new ESRD patients who also received a planned start of renal replacement therapy, likely improving the quality of care ultimately provided.
• Had no material impact on quality measures which remain largely unchanged, except that:
• Under the KCF Model, CMS observed a decline in arteriovenous fistulas of 5.3 percentage points (or 9%); and
  • Under the CKCC Model, CMS observed a 6.9 percentage point (or 16%) increase in Optimal ESRD Starts.[6], which is one of the quality measures tied to performance-based payments.[7]
• Had no material impact on the total payments under Medicare Parts A and B per patient per month, nor did it result in a statistically significant net savings or loss for the Medicare program, except that nephrology practices participating in the KCF Model experienced a potentially meaningful decline of $134 (or 3%) in total Medicare Parts A & B per patient per month payments.[8]
• Resulted in a small increase in evaluation and management payments of approximately $1 per patient per month and total dialysis payments $28 per patient per month under the CKCC Model.[9]
• Increased the proportion of patients with ESRD receiving dialysis treatment at home, while also significantly increasing use of peritoneal dialysis.[10]
• The KCF Model did not affect kidney transplant rates, but the CKCC Model increased the number of patients with an active waitlist status.[11]

In addition, the Report noted that participants in the KCC Model generally received certain benefit enhancements, increased screens for social needs, participated in learning system activities, developed stronger partner relationships, and improved low patient active scores.[12]

Looking Ahead

CMS concluded the Report with optimism, citing that it will be vital to continue evaluations to determine whether early trends persist.[13] The KCC Model is currently set to run for 5 years and CMS will continue to monitor trends and performance. As a result, current participants will have additional opportunities to test the viability of the KCC Model.

FOOTNOTES

[1] Report, at p. 10.

[2] Id.

[3] Id.

[4] Id.

[5] Id. KCEs are organizations formed by nephrology practices, transplant providers, and other options partners.

[6] Id. at p. 16.

[7] Id.

[8] Id.

[9] Id. at p. 15.

[10] Id. at p. 12.

[11] Id. at p. 15.

[12] Id. at p. 10.

[13] Id. at p. 19.