CROWNWeb stands for Consolidated Renal Operations in a Web Enabled Network. It is a federal project, now scheduled to start Feb. 1, that will require all dialysis providers to to submit more comprehensive patient data. It aims to improve data consistency, reduce complexity and provide secured electronic data collection. However, Large Dialysis Organizations (LDO) like Fresenius and DaVita are going to be allowed to do batch data submission from the beginning submitting data directly from their computer systems while Small Dialysis Organizations (SDO) must use new, time-consuming manual procedures, much of which is already being collected in other ways. Unfortunately, as now planned, it creates problems with its aggressive implementation schedule and disproportionate data-entry requirements for smaller dialysis centers compared to big national chains. It also means that time that should be spent on patient issues will now be taken up with pushing paper and keystrokes.

I have written the following to my Congresswoman and Senator (I only have one since the other got elected President). You can use this template or write something of your own, but please write. We patients have to get more engaged in dialysis advocacy issues. In the final analysis, they all have to do with preserving our lives.


I am writing this letter to seek your assistance in convincing the Centers for Medicare and Medicaid Services (CMS) to treat small dialysis organizations (SDOs) in a fair and even-handed manner as it implements a new electronic submission program for gaining patient data. I am a dialysis patient whose clinic is ____________ located at __________, City, State Zipcode. It currently serves about _____ patients in your district with End Stage Renal Disease (ESRD).

CMS is currently developing a Web-based system—CROWNWeb—that will enable the agency to gain patient specific information relating to quality of care. The system is scheduled to be implemented on February 1, 2009. I fully support CROWNWeb and the purpose that it will ultimately serve.

My concern is the disparate treatment that my facility will confront during the early implementation stage of this program. Under the current CMS guidelines, all dialysis providers will be required to submit clinical performance measure (CPM) data either by means of batch submission from their existing computer systems or by manually entering the data. The three largest dialysis organizations, which in the aggregate serve two-thirds of all of the Medicare patients on dialysis, will be permitted to enter the data in batches. However, mine will be required to enter all of the required data manually into the CROWNWeb system.

This manual entry of data for each patient is an extremely laborious process and is much more costly than the batch submission process. Further, the manual data entry process is being required of those facilities that can least afford it. My clinic, and scores of others throughout the country, are barely breaking even or have negative Medicare margins. They cannot afford this additional and unnecessary cost. While CMS is aware of the problem, the agency has given no indication that it will change its current requirements. Furthermore, since it appears that the inability of all dialysis organizations to batch submit stems from the CROWNWeb program’s limited software capability, I believe that the data from more than 200,000 of the 300,000 Medicare patients submitted by the three largest dialysis organizations should meet the agency’s need for patient data during the initial implementation phase.

I firmly believe that all dialysis organizations should be treated the same and that anyone that has the computer capability should be allowed to batch submit the data. My position is supported by the Network Executive Directors, the three largest dialysis organizations, and the entire kidney care community. I would certainly be willing to see the continuance of the current program which requires that my clinic provide a 5 percent sampling of its patient data until the CROWNWeb system is fully operational and allows all providers to batch submit.

I would greatly appreciate your contacting Dr. Barry Straube at CMS and indicate your support for my position. I am simply asking that all dialysis centers be treated equitably and that CMS take appropriate steps to minimize the cost impact on those that can least afford it.

Thanking you in advance.

Hi Folks
Hi Rich, Do you mind if I copy your letter format and take it to my center. I’ve been talking to my center people ,but sadly we are so far apart in travel that I can’t go anymore than the once a month trip right now. I want to help them in order to help more in center folks think about home dialysis. Outside sending letters or email is there anything we can at the centers that might them? My center is small non profit with only two or three centers( I think it only two). I would hate to see them go under.

Bob O’Brien

Bob, I don’t mind at all if you copy it. I basically edited another form letter which was for dialysis center administrators.

Washington State’s entire Congressional delegation supports rethink of CROWNweb implementation

The Northwest Kidney Centers has posted a letter (PDF link) signed by Washington State’s 2 Senators and 9 Representatives to CMS’s acting administrator Kerry Weems and CMS’s Medical Officer Dr. Straube. The Washington State delegation’s letter asks CMS to address the administrative burden of the CROWN. It follows the lobbying and letter writing by the Northwest Kidney Centers and other small dialysis providers concerned about the stupid way CROWNweb is being implemented.

There is just a month left before CROWNweb is due to come online. Not much time but a lot can be done in a month if people are willing to make the effort. Plenty of time to keep nurses doing nursing, rather than data entry.

CROWNweb advocacy opportunity

CMS Medical Director Dr. Barry Straube
CMS Acting Administrator Kerry Weems

If you’d like to help small dialysis providers - actually all providers who are not DaVita, FMC or DCI - then please take a moment to send an email to Dr. Straub and Kerry Weems concerning the implementation of CROWNweb in 5 weeks. For background on the issue I have three posts up on DSEN:

[li]The administrative burden of the CROWN[/li][li]CROWNweb implementation cost data[/li][li]Washington State’s entire Congressional delegation supports rethink of CROWNweb implementation[/li][/ul]

For additional background see the Northwest Kidney Centers and/or the National Renal Administrators Association’s coverage
My bottom line message has been that we need to keep nurses doing nursing, rather than data entry.

CMS rethinks. Delays roll out of CROWNweb

By Bill Peckham

RenalWEB has a Department of Health & Human Services Centers for Medicare & Medicaid Services (CMS) communication posted.
The Centers for Medicare & Medicaid Services (CMS) is pleased to announce that the renal CROWNWeb system will move from its testing environment to a production/implementation environment on February 1, 2009. At that time, CMS will launch CROWNWeb to a small, select group of providers across the country—representing both large- and small-dialysis organizations, as well as independent dialysis facilities across the country. CMS will expand implementation as it learns more about how the system functions within individual facilities.

Until facilities are phased in to CROWNWeb implementation, they should continue with their normal business operations and reporting requirements, including using the SIMS, VISION, and paper-based data submissions. Facilities that are not part of the first phase of implementation may continue to meet their requirements under the ESRD conditions for coverage by continuing to use these submission methods.
This is much different than the language in CMS’s CROWNWeb document that was sent out in June to all dialysis facilities (pdf link) (emphasis CMS’s):
The final rule requires the submission and maintenance of electronic patient and provider records for all dialysis facilities in the United States (§494.180(h)). This requirement takes effect on February 1, 2009. To support this mandate, CMS announces CROWNWeb, a web-based software application that all dialysis facilities will be required to use beginning February 1, 2009. Use of CROWNWeb for data submission by February 1, 2009 is mandatory to support CMS’s goals of quality improvement and performance assessment, as well as to ensure prompt claims processing and reimbursement.
I wrote about the problem with CMS’s implementation of this mandate here, here, here and here. Today’s communication from CMS suggests that before CROWNweb is rolled out nationally it will be able to accept batch data from all providers. I also note that today is the date mentioned in the December 23, 2008 letter (pdf link) which was signed by Washington State’s 2 Senators and 9 Representatives. This letter was addressed to CMS’s acting administrator Kerry Weems and CMS’s Medical Officer Dr. Straube. The Washington State delegation’s letter raised concern with the CROWNweb implementation and asked CMS to answer by today.

Congratulations to the National Renal Administrators Association, small dialysis providers and in particular the Northwest Kidney Centers for their successful advocacy on behalf of small providers and ultimately patients. Patients win when nurses can spend their time on taking care of patients, not on doing paper work. Thank you to Washington State’s entire Congressional delegation for once again showing bipartisan support for the countrys dialyzors. And kudos to CMS’s acting administrator Kerry Weems and CMS’s Medical Officer Dr. Straube for reconsidering the issue and taking a step back. This is good news.

Bill, I’m not sure if I read the same ias you nto the new language. There’s no doubt that there has been a delay in implementing CROWNweb for all, but it wasn’t clear to me that the SDO’s in the initial phase are going to be allowed to do batch processing, or will have to do the individual postings of patient data on the web.

Right now unless you are selected for the initial phase you are suppose to continue to do what you’re doing - which is submitting a five percent sample. This allows the status quo until batch processing of all data sets is accommodated.

That’s what I understood it to mean. Hopefully all centers will be allowed to do batch processing when it finally gets implemented.