Industry experts criticize the QIP because of its structure – it withholds payments, rather than reward facilities for quality of care.

“It should provide an incentive for the people in the bottom quartile to move up and it really doesn’t if it’s just a penalty system,” says Zumwalt.

Providers believe that CMS shouldn’t just hold back the money but rather reinvest it into the program.

“If you have facilities that don’t achieve the right outcomes and money is held back from them, we believe that money should stay within the ESRD program and in turn, should be potentially given to those facilities that do meet the outcomes,” says Satellite’s Cellini.

Patient advocates side with providers, agreeing that QIP should reward those who improve the quality of their care.

“We’d have hoped that there’d be more carrot than stick,” says DPC’s Lennox.
Another concern raised by industry experts is the potential for the alienation of high-risk patients from treatment.

“Patients who do not fit the ideal profile for an in-center dialysis patient might find that there is cherry-picking and also that they might be discharged from a dialysis facility,” says National Kidney Foundation’s Chianchiano, “because dialysis facilities reimbursement under the quality improvement program will be at least partially determined by patient outcomes, which are partially determined by patient adherence to the treatment regiments, such as showing up for dialysis treatments.”

As the proposed rule stands now, payments for quality won’t be impacted until 2012, but CMS plans to use this year’s performance measures, a decision that elicits criticism from the industry. In a letter recently sent to the agency, DaVita argues using 2010 performance measures is a violation of the statute.

MIPPA of 2008 states that CMS must finalize the performance measures before the performance year begins, explains Zumwalt. However, with most of 2010 elapsed, CMS is still finalizing the performance measures it plans to take into consideration in the QIP.
Providers and patient advocates alike are calling for more performance measures beyond hemoglobin levels and anemia management, so that facilities have an incentive to improve “the whole spectrum of ESRD care,” says Chianchiano.

Industry stakeholders also say they are still waiting for the complete implementation of CrownWeb, CMS’ Web-based data collection system that enables dialysis providers to submit patient data to the agency.

Industry players hope to see their feedback to the proposed QIP taken into account in the final rule.

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