Home Dialyzors United (HDU) appreciates the opportunity to comment on the proposed CY2022 End-Stage Renal Disease (ESRD) Prospective Payment System (PPS). We heartily applaud the Centers for Medicare and Medicaid Services (CMS) for focusing this year’s proposed rule on home dialysis and the many health inequities that are inherent in kidney care.

The mission of HDU is to inform, inspire, and advocate for an extraordinary quality of life for the home dialysis community. To that end, we have commented on the CMS Proposed Rule every year, with this year being no exception. We choose not to comment on the document in its entirety, but instead to comment on all aspects of the CY 2022 Changes to the Proposed Rule that we believe impact the home dialysis community.

HDU has submitted our comments in separate and detailed document, accessible on our website www.homedialyzorsunited.org These comments focus on:

·        Ensuring the criteria for the Transitional Payment for Innovative ESRD Equipment and Supplies (TPNIES) includes the views and perspectives of home dialysis patients.

·        Developing a home dialysis quality roadmap based on key domains of home dialysis quality: Home dialysis access, clinical care, safety, retention, and quality of Life (QoL).

·        Modifying the Kt/V Dialysis Adequacy Measure to allow for greater flexibility to prescribe individualized dialysis prescriptions.

·        Looking beyond the various levels of QIP measures by race, ethnicity, and dual status to consider what CMS can do to close known health equity gaps.

·        Clearing the backlog in certifying home dialysis programs. 

·        Waiving the 20% coinsurance for beneficiaries receiving individual Kidney Disease Education (KDE) and KDE in groups.

·        Instituting an accreditation model for KDE content to improve the quality of education provided through the benefit.

·        For the purposes of the ETC model and the QIP, acknowledging that the Home Dialysis Care Experience (Home-DCE) instrument and other beneficiary experience measures do not capture domains of quality of life that are vital for home patients.

Please add your comments in support of any or all of the above issues that HDU is asking CMS to address. Feel free to add or subtract your own concerns. Be candid and tell them what you want.