Measure Description
The measure tracks dialysis patients who are under the age of 75 in a practitioner group and on the kidney or kidneypancreas transplant waitlist (all patients or patients in active status). This measure is a risk-adjusted percentage of waitlist events among dialysis patients.
Instructions
This measure data is to be submitted a minimum of once per month for patients seen during the performance period. This measure is intended to reflect the quality of services provided for patients on dialysis with a diagnosis for EndStage Renal Disease. This measure may be submitted by Merit-based Incentive Payment System (MIPS) eligible groups who provide the measure-specific denominator coding. This measure is not intended to be reported by individual clinicians.
This measure will be calculated with 2 performance rates:
1) Percentage of Prevalent Patients Waitlisted (PPPW)
2) Percentage of Prevalent Patients Waitlisted in Active Status (aPPPW)
For accountability reporting in the CMS MIPS program, the rate for Submission Criteria 2 is used for performance.
Technical notes describing the statistical methods used to calculate the measure, including model details, can be found on the following publicly available webpage: https://dialysisdata.org/content/MIPS. Please refer to the technical notes when calculating this measure.
NOTE: Eligible Cases for this measure conducted via telehealth are not allowable.
Measure Submission Type:
Measure data may be submitted by MIPS eligible groups or third-party intermediaries. The listed denominator criteria are used to identify the intended patient population. The numerator options included in this specification are used to submit the quality actions as allowed by the measure. The quality data codes listed do not need to be submitted by MIPS eligible groups or third-party intermediaries that utilize this modality for submissions; however, these codes may be submitted for those third-party intermediaries that utilize Medicare Part B claims data. For more information regarding Application Programming Interface (API), please refer to the Quality Payment Program (QPP) website.
DENOMINATOR (SUBMISSION CRITERIA 1):
All risk-adjusted patient-months for patients who are under the age of 75 in the reporting month and who are assigned to a dialysis practitioner or practitioner group practice according to each patient’s treatment history on the last day of each reporting month during the performance year.
Definitions:
End-Stage Renal Disease (ESRD) Monthly Capitated Payment (MCP) – An ESRD MCP is a monthly payment made to physicians for dialysis-related physician services provided to Medicare ESRD patients.
Risk-Adjusted Months on the Waitlist – The risk-adjusted number of patient-months on the waitlist is calculated from a mixed-effects logistic regression model, adjusting for age, patient comorbidities, other risk factors at incidence of dialysis, random effects for transplant centers and assuming the practitioner groupspecific event rate equals the population average.
Reporting Month – The last day of each calendar month.
DENOMINATOR NOTE: All patients who meet the denominator inclusion criteria are included and used to model a given dialysis practitioner group's risk-adjusted waitlist rate. The Nursing Home Minimum Dataset (MDS) and Questions 16u and 22 on CMS Medical Evidence Form 2728 may be used to identify patients in skilled nursing facilities.
For the purposes of this measure, the transplant program or Organ Procurement and Transplant Network (OPTN) can be utilized as the data source for the numerator as well as patients on the kidney/kidney-pancreas waitlist prior to the initiation of dialysis.
For more information on how to calculate the risk-adjusted months on the waitlist and observed months on the waitlist please see please see the technical notes found at https://dialysisdata.org/content/MIPS.
If a dialysis practitioner group has fewer than 11 patients during the performance year, the dialysis practitioner group is excluded from reporting outcomes.
Denominator Criteria (Eligible Cases):
All patients aged <75 years old on the last day of the reporting month
AND
Receiving ESRD MCP dialysis services by the provider on the last day of the reporting month: M1269
AND NOT
DENOMINATOR EXCLUSIONS:
Patients who were admitted to a skilled nursing facility (SNF) during the month of evaluation were excluded from that month: M1274
OR
Patients who were admitted to a skilled nursing facility (SNF) within one year of dialysis initiation according to the CMS-2728 form: M1273
OR
Patients determined to be in hospice were excluded from month of evaluation and the remainder of reporting period: M1275
OR
Patients with dementia at any time prior to or during the month: M1271
NUMERATOR (SUBMISSION CRITERIA 1):
Percentage of Prevalent Patients Waitlisted (PPPW): Patients in the practitioner group’s denominator with observed months on the waitlist for each month
Definition:
Observed Months on the Waitlist – The number of patient-months on the waitlist in a practitioner group.
NUMERATOR NOTE: For the purposes of this measure, the transplant program or Organ Procurement and Transplant Network (OPTN) can be utilized as the data source for the numerator.
Numerator Options:
Performance Met: Patients observed on any kidney or kidney-pancreas transplant waitlist as of the last day of each month during the measurement period (M1272)
OR
Performance Not Met: Patients not on any kidney or kidney-pancreas transplant waitlist as of the last day of each month during the measurement period (M1270)
DENOMINATOR (SUBMISSION CRITERIA 2):
All risk-adjusted patient-months for patients who are under the age of 75 in the reporting month and who are assigned to a dialysis practitioner or practitioner group practice according to each patient’s treatment history on the last day of each reporting month during the performance year.
Definitions:
End-Stage Renal Disease (ESRD) Monthly Capitated Payment (MCP) – An ESRD MCP is a monthly payment made to physicians for dialysis-related physician services provided to Medicare ESRD patients.
Risk-Adjusted Months on the Waitlist in Active Status – The risk-adjusted number of patient-months on the waitlist in active status is calculated from a mixed-effects logistic regression model, adjusting for age, patient comorbidities, other risk factors at incidence of dialysis, random effects for transplant centers and assuming the practitioner group-specific event rate equals the population average.
Reporting Month – The last day of each calendar month.
DENOMINATOR NOTE: All patients who meet the denominator inclusion criteria are included and used to model a given dialysis practitioner group's risk-adjusted waitlist rate. The Nursing Home Minimum Dataset (MDS) and Questions 16u and 22 on CMS Medical Evidence Form 2728 may be used to identify patients in skilled nursing facilities.
For the purposes of this measure, the transplant program or Organ Procurement and Transplant Network (OPTN) can be utilized as the data source for the numerator as well as patients on the kidney/kidney-pancreas waitlist prior to the initiation of dialysis.
For more information on how to calculate the risk-adjusted months on the waitlist in active status and observed months on the waitlist in active status please see please see the technical notes found at https://dialysisdata.org/content/MIPS.
If a dialysis practitioner group has fewer than 11 patients during the performance year, the dialysis practitioner group is excluded from reporting outcomes.
Denominator Criteria (Eligible Cases):
All patients aged <75 years old on the last day of the reporting month
AND
Receiving ESRD MCP dialysis services by the provider on the last day of the reporting month: M1269
AND NOT
DENOMINATOR EXCLUSIONS:
Patients who were admitted to a skilled nursing facility (SNF) during the month of evaluation were excluded from that month: M1274
OR
Patients who were admitted to a skilled nursing facility (SNF) within one year of dialysis initiation according to the CMS-2728 form: M1273
OR
Patients determined to be in hospice were excluded from month of evaluation and the remainder of reporting period: M1275
OR
Patients with dementia at any time prior to or during the month: M1271
NUMERATOR (SUBMISSION CRITERIA 2):
Percentage of Prevalent Patients Waitlisted in Active Status (aPPPW): Patients in the practitioner group’s denominator with observed months on the waitlist in active status for each month
Definition:
Observed Months on the Waitlist in Active Status – Observed number of patient-months on the wait list in active status in a practitioner group.
NUMERATOR NOTE: For the purposes of this measure, the transplant program or Organ Procurement and Transplant Network (OPTN) can be utilized as the data source for the numerator.
For more information on how to calculate the risk-adjusted months on the waitlist in active status and observed months on the waitlist in active status please see please see the technical notes found at https://dialysisdata.org/content/MIPS.
Numerator Options:
Performance Met: Patients observed in active status on any kidney or kidney-pancreas transplant waitlist as of the last day of each month during the measurement period (M1268)
OR
Performance Not Met: Patients not observed in active status on any kidney or kidney-pancreas transplant waitlist as of the last day of each month during the measurement period (M1267)
Rationale
A measure focusing on waitlisting is appropriate for several reasons. First, in preparing patients for suitability for waitlisting, dialysis practitioners optimize their health and functional status, improving their overall health state. Second, waitlisting is a necessary step prior to potential receipt of a kidney transplant, which is known to be beneficial for survival and quality of life [1]. Third, dialysis practitioners exert substantial control over the processes that result in waitlisting. This includes proper education of dialysis patients on the option for transplant, referral of appropriate patients to a transplant center for evaluation, and assisting patients with completion of the transplant evaluation process, in order to increase their candidacy for transplant waitlisting. These types of activities are included as part of the conditions for coverage for Medicare certification of ESRD dialysis facilities. Finally, wide regional and facility variations in waitlisting rates highlight substantial room for improvement for this measure [2-5].
The PPPW and aPPPW measures focus specifically on the prevalent dialysis population, examining waitlisting status or waitlisting in active status, monthly for each patient, respectively. As this measure assesses monthly waitlisting status or waitlisting in active status of patients, it evaluates and encourages maintenance of patients on the waitlist which is important given the long duration most patients have to wait to eventually access a deceased donor transplant (national median of roughly 4 years) [6]. In particular, maintenance of active status requires ongoing attention by dialysis practitioners to optimizing the health of patients, to ensure sustained suitability for transplant waitlisting. Maintenance of active status on the waitlist is additionally important given demonstrated disparities [7] and positive association with subsequent transplantation [8]. Overall, maintenance of patients on the waitlist is an important area to which dialysis practitioners can contribute through ensuring patients remain healthy, and complete any ongoing testing activities required to remain on the waitlist. In contrast to this measure, other waitlisting measures, such as the First Year Standardized Waitlist Ratio, focus solely on new waitlistings and living donor kidney transplants to incentivize early action, rather than ongoing maintenance on the waitlist, as this measure does.
References
1. Tonelli M, Wiebe N, Knoll G, et al. Systematic review: kidney transplantation compared with dialysis in clinically relevant outcomes. American Journal of Transplantation 2011;11:2093-2109.
2. Ashby VB, Kalbfleisch JD, Wolfe RA, et al. Geographic variability in access to primary kidney transplantation in the United States, 1996-2005. American Journal of Transplantation 2007; 7 (5 Part 2):1412-1423.
3. Satayathum S, Pisoni RL, McCullough KP, et al. Kidney transplantation and wait-listing rates from the international Dialysis Outcomes and Practice Patterns Study (DOPPS). Kidney Intl 2005 Jul; 68 (1):330-337.
4. Patzer RE, Plantinga L, Krisher J, Pastan SO. Dialysis facility and network factors associated with low kidney transplantation rates among United States dialysis facilities. Am J Transplant. 2014 Jul; 14(7):1562-72.
5. Melanson TA, Gander JC, Rossi A, et al. Variation in Waitlisting Rates at the Dialysis Facility Level in the Context of Goals for Improving Kidney Health in the United States. Kidney International Reports 2021;6:1965-1968. No abstract.
6. United States Renal Data System. 2020 USRDS Annual Data Report: Epidemiology of kidney disease in the United States. National Institutes of Health, National Institute of Diabetes and Digestive and Kidney Diseases, Bethesda, MD, 2020.
7. Kulkarni S, Ladin K, Haakinson D, et al. Association of Racial Disparities With Access to Kidney Transplant After the Implementation of the New Kidney Allocation System. JAMA Surg 2019; 154(7):618-625.
8. Grams, M. E., Massie, A. B., Schold, J. D., Chen, B. P., & Segev, D. L. (2013). Trends in the inactive kidney transplant waitlist and implications for candidate survival. American Journal of Transplantation, 13(4), 1012-1018.
Clinical Recommendation Statements
Empirical support for the value of waitlisting to patients comes from a published study reporting on a large survey of 409 patients or family members who agreed to receiving emails from the National Kidney Foundation [1]. Participants include both patients with advanced chronic kidney disease prior to transplant, and recipients of transplants, and were asked about their priorities in choice of a transplant center. Notably, participants were most likely (a plurality of participants) to rank waitlisting characteristics (such as ease of getting on the waitlist) as the most important feature, in contrast to other transplant center characteristics such as post-transplant outcomes and practical considerations (e.g., distance to center).
National or large regional studies provide strong empirical support for the association between processes under dialysis practitioner control and subsequent waitlisting. In one large regional study conducted on facilities in the state of Georgia, a standardized dialysis facility referral ratio was developed, adjusted for age, demographics and comorbidities [2]. There was substantial variability across dialysis facilities in referral rates, and a Spearman correlation performed between ranking on the referral ratio and dialysis facility waitlist rates was highly significant (r=0.35, p3) transplant education strategies (e.g., provision of brochures, referral to formal transplant education program, distribution of transplant center contact information) had 36% higher waitlist rates compared to facilities employing fewer strategies.
References
1. Husain SA, Brennan C, Michelson A, Tsapepas D, Patzer RE, Schold JD, Mohan S. Patients prioritize waitlist over posttransplant outcomes when evaluating kidney transplant centers. Am J Transplant. 2018 Nov;18(11):2781-2790.
2. Paul S, Plantinga LC, Pastan SO, Gander JC, Mohan S, Patzer RE. Standardized Transplantation Referral Ratio to Assess Performance of Transplant Referral among Dialysis Facilities. Clin J Am Soc Nephrol. 2018 Feb 7;13(2):282-289.
3. Kucirka LM, Grams ME, Balhara KS, Jaar BG, Segev DL. Disparities in provision of transplant information affect access to kidney transplantation. Am J Transplant. 2012 Feb;12(2):351-7.
4. Salter ML, Orandi B, McAdams-DeMarco MA, Law A, Meoni LA, Jaar BG, Sozio SM, Kao WH, Parekh RS, Segev DL. Patient- and provider-reported information about transplantation and subsequent waitlisting. J Am Soc Nephrol. 2014 Dec;25(12):2871-7.
5. Waterman AD, Peipert JD, Goalby CJ, Dinkel KM, Xiao H, Lentine KL. Assessing Transplant Education Practices in Dialysis Centers: Comparing Educator Reported and Medicare Data. Clin J Am Soc Nephrol. 2015 Sep 4;10(9):1617-25.