The Coalition for Kidney Supportive Care has formally submitted comments to the Centers for Medicare & Medicaid Services (CMS) regarding the CY 2027 End-Stage Renal Disease (ESRD) Prospective Payment System Proposed Rule (CMS-1846-P). In the proposed rule, CMS acknowledges palliative dialysis and notes that seriously ill patients deserve tailored, goal-concordant options. The Coalition's comments focused on how to address payment and measurement barriers to ensure uptake and adoption of these important aspects of kidney supportive care.
Key recommendations from our submission include:
- Adopt Shared Decision-Making Measures: We recommend a validated tool called CollaboRATE over the static Dialysis Patient Life Goals survey to ensure true patient engagement without administrative bloat.
- Define Palliative Dialysis by Intent, Not Modality: Eligibility should prioritize patient goals, comfort, and prognosis, not restricted to hospice or 6-month timelines.
- Protect Facilities from Metric Penalties: Patients receiving palliative dialysis must be excluded from standard quality incentive program metrics so centers aren't financially penalized for prioritizing comfort over lab targets.
- Enable Concurrent Hospice & Dialysis: Establish a clear payment pathway allowing patients on hospice to receive concurrent palliative dialysis for symptom relief, removing the forced choice between hospice and dialysis.
Empower the Interdisciplinary Team: Utilize nephrology nurses and Advanced Practice Providers at the top of their licenses to lead continuous goals-of-care conversations.