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DOH Provides Further Information on Nursing Home Dialysis Model

The Department of Health (DOH) has just issued an updated Frequently Asked Questions (FAQ) document on the State licensure requirements for hemodialysis services provided to nursing home residents through partnerships between nursing homes and end-stage renal dialysis (ESRD) providers. These FAQs include important information on the Certificate of Need (CON) Limited Review Application (LRA) process and the programmatic, contractual, staffing, and architectural requirements for nursing homes seeking to partner with ESRD providers to establish dialysis services for residents.

There are two models of home hemodialysis service delivery that can be licensed in this way: 1) dialysis at the resident’s bedside; and 2) dialysis in a dedicated treatment room in the nursing home, also known as a “den.” Both require the involvement of a certified dialysis provider. The Centers for Medicare and Medicaid Services (CMS) allows ESRD providers to offer these services if they are already federally certified in Home Hemodialysis Training and Support.

Importantly, the FAQ document clarifies that:

  • Applicants for one or more treatment rooms must also be able to meet the architectural, engineering, and staffing requirements for bedside programs so that they can dialyze patients at the bedside in cases where isolation is required.
  • This program only allows nursing homes to provide services for their residents. Facilities seeking to provide services for outpatients must be licensed to operate a diagnostic and treatment center in a separate and distinct space.
  • Nursing homes that have already been approved for bedside dialysis or a den do not need to submit an LRA, but any subsequent plans to construct a den or additional den will require LRA submission.
  • Nursing homes will not be allowed to construct a den on a residential unit and move all residents needing dialysis to that floor. According to DOH, a resident cannot be relocated simply for the convenience of staff or grouped by diagnosis. DOH is also discouraging locating a den on a residential floor but is willing to consider it on a case-by-case basis only if the proposed location does not require traversing the residential unit to access the service.

By way of review, DOH’s licensure process includes the following steps:

  • A nursing home seeking to offer dialysis services on-site must submit an LRA through the New York State Electronic CON (NYSE-CON) system to add the service of Nursing Home Hemodialysis or Nursing Home Hemodialysis-Bedside Only to their operating certificate.
  • The nursing home must establish an agreement with an ESRD provider that has a fixed location, has been federally certified in Home Hemodialysis Training and Support, and has been State-licensed or has submitted an LRA to be State-licensed in Nursing Home Hemodialysis. CMS Dialysis Facility Compare currently identifies 324 dialysis facilities in New York and displays the quality ratings and other information on each provider for your review. Of this total, 93 are approved to offer Home Hemodialysis Training and Support.
  • If the nursing home is only performing bedside hemodialysis, an initial survey will be at DOH’s discretion. Approval will be based on the review of the agreement between the nursing home and the ESRD provider, as well as policies and procedures and environmental checklists uploaded through the NYSE-CON system.
  • If the application is for the construction of a treatment room, in addition to a review of the materials uploaded through NYSE-CON, approval will require an on-site pre-opening survey. A separate LRA must be submitted for any subsequent dens in the same facility.

DOH has posted more details on the application process and licensure of these services on its website, including Guidance and Instructions for Submitting a Limited Review Application for Nursing Home Hemodialysis Services.

Nursing home patients/residents requiring hemodialysis services typically are transported to a regular dialysis center three times a week. Providing hemodialysis services in the nursing home eliminates the need for patients to endure these disruptive and risky transports and allows them to spend more time receiving therapy and working to improve their condition and prospects for discharge. With the increased communication between the nursing home and the dialysis provider that results from these arrangements, quality of care can also be enhanced, in addition to a better quality of life.

Contact: Dan Heim, dheim@leadingageny.org, 518-867-8866