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Prospective to Improve ESCO Program

April 18, 2014

Dear Mr. Blum and Dr. Conway:

On behalf of the undersigned patient and health professional organizations, thank you for meeting with us Wednesday, September 18, 2013. Our organizations were all grateful for the opportunity to listen to CMS’ perspectives on the ESCO Program and discuss our recommendations to strengthen the program.

In response to your request, please find attached our organizations’ recommendations regarding the existing quality measures we believe should be included in the ESCO evaluation. (Appendix 1.) Of the existing quality measures, we believe those listed have the most rigorous evidence base and are the most likely to help meaningfully improve outcomes from a patient perspective. Also attached are our organizations’ recommendations regarding “areas for surveillance”—aspects of care which are crucial to monitor, but for which no quality measures currently exist. (Appendix 2.) We appreciate the opportunity to share these lists with you and your staffs.

Our organizations understand that CMMI has contracted with IMPAQ, which recently released the Technical Expert Panel (TEP) quality measure recommendations for the ESCO program. Most, if not all, of the undersigned organizations have independently responded to the request for comments regarding the TEP’s recommendations that was due by March 31. We have also indicated where measures that our group believes should be considered were also recommended by the TEP. However, this letter is not intended as a comprehensive response to the TEP convened by IMPAQ, but rather a response to the request for our organizations’ input on which measures we believe should be included in the ESCO program.

As you are aware, the patient population that will be part of the ESCO program will be unique, vulnerable, and highly complex. As such, we urge CMS and CMMI to ensure that all measures selected for the ESCO program are appropriate for people on dialysis. Although many existing measures in the Accountable Care Organization program and other Medicare programs are appropriate for the primary care/patient population, they are often not applicable to people with ESRD. The attached list of

recommended measures reflects this perspective. Importantly, while our organizations are submitting comments regarding metrics that warrant consideration for the ESCOs, all ESCO applicants in collaboration with CMMI should determine which measures should be used in this project.

Our organizations believe that surveys are an important part of verifying patient satisfaction and experience of care and have included three patient surveys on our list of recommended measures for the ESCO program. However, we recognize that survey fatigue can be a challenge for both patients and staff, and encourage CMS and CMMI to think carefully regarding when and where ESCOs are asked to administer surveys to minimize duplication of information.

Our organizations also observe that there is currently a dearth of measures that are appropriate to assess the care of patients on peritoneal dialysis and home hemodialysis. While we recognize that CMS and CMMI are considering only existing measures, our organizations urge you and your staffs to keep this unique and growing patient population in mind when developing and assessing the ESCO program.

Once again, our organizations appreciate the opportunity to share our input and experiences in these important areas, and we look forward to our continued collaboration in the future. Our organizations believe that the ESCO program has real potential to reduce costs and improve patient care, and appreciate the opportunity to work in partnership to help ensure the program is as strong as possible.

If you have any questions or concerns regarding this email or the attached documents, please do not hesitate to contact any of our organizations. An organizational contact sheet is included in this correspondence.

Again, thanks.


American Association of Kidney Patients
American Kidney Fund
American Nephrology Nurses Association
American Society of Nephrology
American Society of Pediatric Nephrology
Dialysis Patient Citizens
Renal Physicians Association
Renal Support Network