CMS Updates Kidney Care Choices Model
The Center for Medicare and Medicaid Innovation ("CMMI") announced sweeping changes to the Kidney Care Choices Model ("KCC Model"), a key set of value-based programs.
On May 28, 2025, CMMI announced its new approach to the KCC Model, citing a need to improve the KCC Model's financial sustainability after recording approximately $304 million in net losses. These changes are part of a Trump administration strategy to increase CMMI operational efficiency (highlighted in our previous Alert) and chart a new course for value-based care.
CMMI introduced the KCC Model in 2019 with the intent to reduce cost and improve quality of care for patients with late-stage chronic kidney disease ("CKD") and end-stage renal disease ("ESRD"). Since its implementation, the Centers for Medicare & Medicaid Services ("CMS") reported that the KCC Model improved quality of care but increased spending. The KCC Model currently includes four Comprehensive Kidney Care Contracting ("CKCC") options: (i) the Kidney Care First ("KCF") Option; (ii) the Graduated Option; (iii) the Professional Option; and (iv) the Global Option.
Highlights of CMMI's changes to the KCC Model include:
- Early Termination of the KCF Option: CMMI is terminating the KCF option a year early, requiring affected nephrology practices to complete a close-out process by December 31, 2025.
- Extension of Other CKCC Options: The Graduated, Professional, and Global options are extended through December 31, 2027.
- Expanded Benchmark Discounts: From 2026 onwards, CMMI is adding a 1% discount on Global risk participants for CKD benchmarks and a 1% discount on Professional risk participants for both benchmarks. Discounts under KCC Models (and other value-based programs) create a higher threshold for receipt of shared savings and can reduce financial opportunities via shared savings participation.
- Elimination of Kidney Transplant Bonus: Previous policy, which allowed KCF participants and Kidney Care Entities to receive up to $15,000 per successful transplant, will cease starting in 2026.
- Cuts to Capitation Payments: Quarterly capitation payments for CKD beneficiaries, which Participants receive in lieu of evaluation and management fee-for-service claims, will be reduced by 50% to align payments with fee-for-service amounts. Coupled with the elimination of transplant bonuses and the expansion of benchmark discounts, participants in KCC Models should prepare for reduced revenue from the program going forward, except to the extent that such participants are able to enhance their quality and efficiency results within the kidney care model programs.
