Corporate Compliance

ESRD Conditions of Coverage

Compliance Monitor, May 5, 2005

Q: What were the fundamental principles that guided the development of the new ESRD Conditions of Coverage?

A: In 2000, the Office of Inspector General (OIG) of the Department of Health and Human Services (HHS) conducted an extensive review to ascertain the effectiveness of the monitoring of the ESRD program. Their subsequent report, "External Quality Review of Dialysis Facilities: A Call for Greater Accountability," was published in June 2000.

Three main problem areas were found:

  • Infrequent number of on-site compliance surveys
  • The CMS enforcement approach does not provide incentives for dialysis facilities to stay in compliance with Medicare requirements
  • State agencies and ESRD networks do not share information about complaints and quality of care problems at facilities

In response to the need for greater accountability in the ESRD program, a new subpart H has been added to the proposed conditions to read as follows: "Subpart H-Termination of Medicare Coverage and Alternative Sanctions for ESRD Facilities." To view the proposed conditions of coverage, click here. To read Subpart H, scroll to p. 6245.

This question was answered by Carrie L. McGinnis, RN, MBA, chief executive officer, Healthcare Design Specialists, Springfield, MO.

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