CMS Reopens Application for Participation in the Comprehensive ESRD Care Initiative

April 18, 2014

On April 17, the Centers for Medicare & Medicaid Services (CMS) published an announcement regarding the reopening of the application period for ESRD Seamless Care Organizations (ESCO) to participate in the testing of its Comprehensive End-Stage Renal Disease (ESRD) Care initiative. 79 Fed. Reg. 21736. CMS also issued a new request for application (RFA) for participation that reflects the revisions to the design of the Comprehensive ESRD Care initiative, since the original application period for participation in the initiative was closed on Aug. 13, 2013.

In connection with the reopening, the Center for Medicare & Medicaid Innovation (CMMI) announced that it will host a Special Open Door Forum to allow dialysis facilities, nephrologists, other Medicare providers of services, suppliers and other interested parties to ask questions about the revisions to the revised RFA on Thursday, April 24, from 2 to 3:30 p.m. Eastern time.

The announcement regarding the Special Open Door Forum explains that CMS has worked with stakeholders to revise the initiative to allow for broader participation by both large dialysis organizations (LDOs), which are organizations that each own more than 200 dialysis facilities, and non-LDOs. These revisions include (1) revisions to participant owner requirements; (2) alterations to the financial risk arrangement; and (3) the inclusion of an option for non-LDOs to aggregate data with other non-LDOs for the purpose of certain financial calculations. According to the CMMI, the revisions are intended to address concerns regarding financial arrangements, the inability of non-LDOs to satisfy the matched beneficiary requirement and the barrier to non-LDO participation caused by the previously high minimum savings rate. (For information regarding the original RFA, please see the article published last year by McGuireWoods LLP.)

Interested ESCOs that include at least one LDO applicant must submit a letter of intent and application no later than June 23, 2014. Interested ESCOs without LDO applicants must submit a letter of intent and application no later than Sept. 15, 2014.

For more information, the announcement of the reopening of the application period is available at and the revised RFA may be found at Additional information regarding the Special Open Door Forum can be accessed at