CMS Proposes Mandatory Medicare Payment Model for Kidney Transplants

The United States Centers for Medicare and Medicaid Services (CMS) recently proposed a new mandatory Medicare payment model to test whether performance-based incentives for hospitals may improve the system and better connect patients who need kidney transplants with the needed organs.

CMS notes that kidney transplantation is often the best method of treatment for patients with chronic kidney disease and end-stage renal disease but that there are more people that need a kidney than there are organs available. The goal of the proposed model is to “drive meaningful growth” in the kidney transplant rate by maximizing the use of deceased donor kidneys and facilitating more transplants from living donors. The proposed model also aims to reduce barriers to care and address health disparities.

Under the proposed Increasing Organ Transplant Access Model, transplant hospitals would be encouraged to use more of the kidneys that become available for transplantation and facilitate more transplants from living donors. The model also aims to improve greater care coordination and patient-centered care in the process of being waitlisted for – and receiving – a kidney transplant.

CMS would select half of the donation service areas (DSAs) and all eligible kidney transplant hospitals within would participate in the mandatory model. The other half of transplant hospitals would serve as the comparison group for evaluation purposes. Eligible hospitals are those that are non-pediatric transplant hospitals with an active kidney transplant program and that perform an annual average of 11 or more kidney transplants in the three baseline years prior to the start of the model in 2025. The model would require data-sharing and provide incentives for participating transplant hospitals to improve the patient experience. Patients would receive a notice of attribution if their transplant hospital participates in the model and would not be limited to their attributed transplant hospital.

Out of the 257 transplant hospitals in the country, about 90 would be required to participate in the model.

Based on the participating transplant hospital’s final performance score, it would either: receive upside risk payments from CMS, fall in a neutral zone and neither receive an upside risk payment nor owe a downside risk payment, or owe downside risk payments to CMS. The final performance score would be out of a total of 100 points and calculated on a set of proposed metrics within three domains: (1) achievement – based on the number of kidney transplants for a total of 60 points; (2) efficiency – based on the organ offer acceptance rate ratio for a total of 20 points; and (3) quality – based on the CollaboRATE Shared Decision-Making Score, Colorectal Cancer Screening, Three-Item Care Transition Measure, and a post-transplant composite graft survival rate measure for a total of 20 points.

“Modernizing the organ transplantation system is a top priority for the Biden-Harris Administration,” said CMS Administrator Chiquita Brooks-LaSure. “Kidney transplantation helps people live healthier and longer lives because they no longer have to undergo dialysis. The Increasing Organ Transplant Access Model would be an important step forward in improving the kidney transplant process for everyone on a waitlist and those who have received a transplant.”

The Increasing Organ Transplant Access Model is a proposed six-year, mandatory model that would begin on January 1, 2025.

For a Fact Sheet on the Model, click here. FAQs can be found here, and a press release here.

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