Table 1.

Policy Initiatives During the COVID-19 Crisis and Proposed Future Directions

	Pre-COVID-19 Policy Infrastructure	Response to COVID-19	Future Directions
Resource management		•Increased dialysate manufacturing •Contingency and crisis strategies with return to work criteria •PPE burn rate calculator	•Strengthen supply chains Increase capacity of staff to support patients on home dialysis
Telemedicine	•Only for home dialysis •Requires HIPAA-compliant, HIPAA-approved, encrypted devices and software •Requires audio and video	•Any patients may use telemedicine •May use standard software, not HIPAA compliant •Waived requirements for both audio and visual input	•Train more providers in telemedicine •Consider relaxed requirements for telehealth use, expand to multidisciplinary care
Dialysis access	•Quality incentives for timely arteriovenous fistula or graft placements	•Access procedures clarified as essential	•Address bottleneck of elective procedures •Consider additional reimbursement to offset competition with high revenue procedures •Pathways for percutaneous access placements
Home dialysis	•Patients using home dialysis may use telehealth •Face-to-face assessments required quarterly	•Suspended quarterly face-to-face requirement •Dialysis facilities allowed to furnish home dialysis at long-term care facilities	•Increase home dialysis infrastructure support •Increased access to telehealth •Consider financial pathway for using outpatient PD for AKI
Administrative burden	•Patients over paperwork Omnibus Burden Reduction (Conditions of Participation) Final Rule	•Deadline extensions for routine auditing, equipment inspections, and CPR certification	•Balance reduction of regulatory burden with patient safety
Quality measures	•MIPS QIP	•Extended MIPS reporting deadline, optional reporting for individuals •January 1, 2020 to June 30,2020 exempt from QIP	•Monitor vascular access outcomes, transplantation, and hospitalization rates •Consider delayed measure implementation

Abbreviations: CPR, cardiopulmonary resuscitation; MIPS, Merit-based Incentive Payment System; QIP, Quality Incentive Program; CMS, Centers for Medicare and Medicaid Services; PPE, Personal Protective Equipment; PD, peritoneal dialysis; AKI, acute kidney injury; CARES Act, Coronavirus Aid, Relief, and Economic Security Act; HIPAA, is Health Insurance Portability and Accountability Act.