New proposed Conditions for Coverage for dialysis are available for public comment until 5 p.m. on May 5, 2005. Patients' voices need to be heard in this process. The non-profit Medical Education Institute (MEI) wants to make it as easy as possible for you to comment.

Why should you care?

The Conditions for Coverage are the regulations that Medicare surveyors use when they inspect clinics. This is the first proposed update of any consequence in 29 years. The Conditions include info on staffing levels (still very vague), staff qualifications, patients' rights, and many other areas that affect quality of care. The MEI is particularly interested in three things:

1) PATIENTS' RIGHTS [494.70 Condition: Patients' Rights]
Today, you DON'T have the right to know about all of the treatment options for kidney failure or where they're offered. You DON'T have the right to learn how to put in your own needs or that there is pain medication to help. And you DON'T have the right to refuse to let someone put in your needles -- even if that person damaged your access the last time. NOTHING prevents the clinic from involuntarily discharging you for failing to show up for treatment or even for drinking too much fluid.

2) FUNCTIONING AND WELL-BEING [494.80(a) Condition: Patient Assessment]
Today, the only things that clinics measure to know how you're doing relate to your blood -- blood pressure, vascular access, anemia, dialysis adequacy. No one is required to assess how dialysis affects your day-to-day life. Physical and emotional functioning have been linked to hospitalizations and even survival. Therefore for staff to help you, they must survey you to ask how you're doing. Please tell Medicare that you want clinics to measure your physical and mental functioning at least twice a year.

3) TECHNICIAN TRAINING [Section 494.140(e) Condition: Personell Qualifications -- Patient Care Dialysis Technicians]
All staff working in dialysis must be licensed, registered, or certified except for patient care dialysis technicians. Beyond the requirement to have a high school diploma and 3 months of on-the-job training, there is no federal requirement for the what specific training a patient care dialysis technician should have. Further, there is no federal requirement for testing patient care technicians' competence if the state does not require it.

You can read the 72-page document and/or comment online from the Home Dialysis Central website (http://www.homedialysis.org). When you comment, include CMS-3818-P and the section number and description (see above). If you'd prefer to mail or hand deliver your comments, you can find these addresses on the second page of the document. Again, the comment period ends May 5, 2005. If you care about any of these or other sections in the Conditions for Coverage, make your voice heard!