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.