Robert Maurice Powell
Analyst · Sanford Bernstein
Yes, so what's happened Lisa is, the program has slipped some. I think that CMS has realized with the magnitude of what they proposed, millions of providers that were looking and thinking about the ESCOs, if you will, have bigger fish to fry. Let me give you a couple of bullet points just so you're aware. CMS is looking for applications. What we find now is they've lagged the timeline a little bit longer. They have made several changes to what was initially proposed. In the very beginning, they were looking for 500 patients, NSI. Now they've dropped that to 350 patients in an ESCO, and that's really -- I think stimulates smaller providers to participate. Last week brought 2 things, 2 changes. They eliminated the requirement for a third Medicare provider other than dialysis clinics and nephrologists. Now we like that because we didn't really understand the sense for CMS requiring us to have outside of ESRD people, another person standing there, if you will, the third leg on the stool. Now if we need to do something, bring somebody else in to improve patient care, we'd be willing to do that, but we wanted to do it voluntarily and not have it rammed down our throat, is the way it was laid out in their proposal. The other thing that they've is they've moved the savings that are required. They've moved them out in time, meaning, that in year 1, where there was supposed to be a 1% savings guaranteed, they've listed no savings in year 1. And then, year 2 is now 1%, et cetera, et cetera. So we've seen a little movement in this. I will tell you that we like what we see this far, but unfortunately, there are still parts of the program that really, in our view, don't incentivize physicians and providers to jump into this in a big way. So I think there's more to do there. But we are totally, totally focused at the moment on what we need to do with this proposed rule, if that makes sense to you.