It's my understanding from a contact at CMS that the Texas rules currently require “all” dialysis units to have a water treatment system with a circulating loop. This probably wasn’t “intended” to include PD only or even places that do only home HD training (esp with NxStage), but that is what the rules say, and what the survey agency is holding every facility to. The TX rules are scheduled to be revised this year, and the Network in Texas has recommended this requirement for the water system be clarified as not applicable for PD only units. It's my understanding that there will need to be discussion about programs like NxStage. This is an area where clinics using NxStage HHD equipment only may want to educate and advocate. I'd contact the TX Network to see what is in the works now.
I also have heard that AAMI is currently developing specific water treatment guidelines for home patients as an Annex for the Dialysate Recommended Practice. You might want to check on the AAMI website periodically for updates. I suspect it would be posted here:
http://www.aami.org/publications/sta.../dialysis.html
Beth Witten MSW ACSW LSCSW
Medical Education Institute, Inc.