Comment on The CMS-3742-P: ESRD Dialysis Patient Life Goals Survey (PaLS)

CMS often works with contractors for different aspects of its programs, including those related to quality measures. Of these contractors, the Partnership for Quality Measurement is responsible for tasks such as developing and maintaining quality measures, collecting and analyzing data, providing technical support to healthcare providers, and ensuring compliance with CMS requirements.

There is a new measure under consideration that is currently open for comments called the ESRD Dialysis Patient Life Goals Survey (PaLS). The PaLS is a patient self-report survey that consists of a check list of questions related to dialysis facility care team discussions about patient life goals. These items are not scored. Instead, these items serve to provide contextual information for both the patient and the facility to guide care team discussions. There are several harmful flaws in this measure. It is important to speak up now and let your voice be heard. There is a detailed letter to CMS from RSN’s Founder and President, Lori Hartwell outlining these concerns in the how to submit comments instruction below. Please click the link text to read the letter before making comments.

The deadline to comment is Friday, Dec 22, 2023

How to Submit Comments

The best comments are direct and personalized. They do not have to be long. We recommend making the points about your life goals being beyond what was included in the survey options:.

  1. Read RSN’s letter from Founder and President Lori Hartwell
  2. Enter your name and email address (and organization if applicable for healthcare professionals)
  3. Select the care setting value: Hospital Committee
  4. Select Hospital Committee Measure: ESRD Dialysis Patient Life Goals Survey (PaLS)
  5. Continue in the comment section to describe your concern about the proposed rule. (Feel free to use comments in RSN’s letter)

Comments can be submitted electronically via the Partnership for Quality Measurement website. When you click this link, you can type your comment directly into the webform.

Partnership for Quality Measurement comment link:

Web ID 8082