Kidney Care Partners Submits Comments on CMS CY26 Medicare Advantage and Part D Advance Notice

Washington, DC, January 31, 2025 --(PR.com)-- Kidney Care Partners (KCP) – the nation’s leading kidney care multi-stakeholder coalition representing patient advocates, physician organizations, health professional groups, dialysis providers, researchers, and manufacturers – recently submitted comments to the Centers for Medicare & Medicaid Services (CMS) in response to its calendar year (CY) 2026 policy and payment proposals for Medicare Advantage Organizations (MAOs).

Given more than half of Medicare beneficiaries have opted into Medicare Advantage plans, KCP appreciates that plan products offered by MAOs are available to patients with kidney failure. Such plans often provide supplemental benefits and services that traditional Medicare does not. These benefits can be especially impactful to patient well-being, including care coordination, nutrition support, healthy grocery allowances, and transportation services. However, KCP is concerned that MAO plan products may not provide timely access to benefits that patients in traditional Medicare receive, including access to innovative and breakthrough drugs, biologicals, and devices.

In its comments, KCP urged CMS to expand access to innovations for individuals living with kidney failure – or end-stage renal disease (ERSD) enrolled in MAO health plans – by reimbursing dialysis care providers directly for special payments associated with Transitional Drug Add-on Payment Adjustment (TDAPA) or Transitional Add-on Payment Adjustment for New and Innovative Equipment and Suppliers (TPNIES) programs, to ensure access to innovative therapies, equipment and supplies prescribed by a patient’s physician.

Currently, CMS does not require MAO plan products to reimburse dialysis facilities for innovative therapies, equipment and supplies that are part of the CMS’ TDAPA or TPNIES programs, leaving patients enrolled in the MA program at a potential clinical disadvantage from their counterparts enrolled in traditional Medicare.

Further, KCP specifically urged CMS to ensure access to TDAPA payment for phosphate binders that were incorporated into the End-Stage Renal Disease Prospective Payment System (ESRD PPS) at the beginning of the year. “Given the critical nature of these products in the effective management of individuals’ phosphate levels, the potential lack of access to the TDAPA adjustment during the two-year transition period could result in a de facto lack of coverage and lead to increased patient morbidity and mortality,” the letter read.

“Those across the kidney disease continuum should be supported by health coverage plans that meet their needs, improve quality of life and provide easy access to care,” said Mahesh Krishnan, MD, MPH, MBA, Chair of KCP. “KCP looks forward to working with CMS to implement policies that improve the care for kidney patients in MA plans and ensure all beneficiaries can access comprehensive care and timely access to innovative treatments.”

To read KCP’s full comment letter, click here.