GNYHA’s recently submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the calendar year 2025 end-stage renal disease (ESRD) prospective payment system (PPS) proposed rule oppose CMS’s proposed wage index methodology changes.
CMS’s proposed rule argued that the current ESRD PPS wage index does not accurately reflect the ESRD facility labor market as it is derived from hospital wage data. CMS cited stakeholder concerns that the types of labor used in ESRD facilities differ from the types used by hospitals, which could result in an inaccurate wage index. CMS proposed to change the methodology by calculating an ESRD-specific wage index using all-employer Bureau of Labor Statistics (BLS) Occupational Employment and Wage Statistics (OEWS) data that would be weighted for ESRD-specific occupations using freestanding ESRD facility cost report data.
GNYHA opposes this change because it discounts the experience of hospital-based ESRD facilities as they do not submit unit-specific cost reports and are therefore excluded from the data used for weighting occupations. GNYHA argued that hospital-based ESRD facilities have labor and hiring practices that are more similar to hospitals than freestanding ESRD facilities and are subject to hospital labor requirements such as staffing plans and collective bargaining agreements. Additionally, GNYHA opposes using BLS OEWS data because it lacks information on employee benefits and self-employed contract labor, which can vary widely across labor market areas. Due to these limitations, GNYHA argued that hospital wage data continues to be the best available data with which to calculate the ESRD PPS wage index.
CMS also proposed to continue to apply a 5% cap on the wage index decreases from the prior year. GNYHA supports the continuation of this policy.