On August 17, 2018, the Centers for Medicare and Medicaid Services (CMS) issued a Memorandum to state survey agency directors regarding Medicare-approved End Stage Renal Disease (ESRD) facilities that provide dialysis services to residents of long-term care nursing facilities. The Memorandum outlines new survey and compliance requirements for ESRD facilities that provide home hemodialysis or peritoneal dialysis services to nursing facility residents, which go into effect on September 17, 2018.
In order to receive Medicare reimbursement for outpatient dialysis services, chronic dialysis patients must be under the care of a certified ESRD facility. Residents of nursing facilities may receive chronic dialysis treatments under two possible arrangements:
- In-Center Dialysis, which means that the resident is either transported to an off-site certified ESRD facility or transported to a separately certified ESRD facility location that is within or proximate to the nursing home building.
- Home Dialysis in a Nursing Home, which means that the resident receives dialysis treatment in the nursing home pursuant to a written agreement between the nursing home and an ESRD facility. Under the home dialysis arrangement, all dialysis treatments are administered and supervised by qualified personnel who meet specific training requirements and competency standards.
The Memorandum addresses the second arrangement for dialysis treatments in the nursing home setting. CMS states that the purpose of the surveys is to ensure that all dialysis treatments are administered in a safe environment by properly trained personnel. Accordingly, the CMS Memorandum and survey guidance place an emphasis on personnel training and qualifications, the coordination of care between the ESRD facility and the nursing facility, and the specific responsibilities of the ESRD facility and the nursing facility.
Most notably, ESRD and nursing facilities should ensure that hemodialysis treatments are supervised by a trained registered nurse and peritoneal dialysis treatments are supervised by either a trained registered nurse or a licensed practical nurse/licensed vocational nurse. In addition, providers can expect surveyors to inspect the written agreements between the ESRD facilities and the nursing facilities. Thus, providers should make sure that their agreements clearly and specifically delineate the responsibilities between the ESRD and nursing facilities as well as outlining the facilities’ shared responsibilities. For example, the ESRD facility should be responsible for verifying the competency and providing ongoing training of personnel administering the dialysis treatment, providing dialysis supplies and medications, and maintaining the dialysis equipment. The nursing facility should be responsible for ensuring a safe environment, providing infection control, and administering supportive care services to residents.
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