Form CMS-2728 Data Versus Erythropoietin Claims Data: Implications for Quality of Care Studies

Abstract

Medical Evidence Report Form CMS-2728 data is frequently used to study US dialysis patients, but the validity of these data have been called into question. We compared predialysis erythropoietin use as recorded on Form CMS-2728 with claims data as part of an assessment of quality of care among hemodialysis patients. Medicare claims were linked to Form CMS-2728 data for 18,870 patients. Dialysis patients, 67 years old or older, who started dialysis from 1 June 2005 to 31 May 2007 were eligible. Logistic and multivariate regressions were used to compare the use of either Form CMS-2728 or the corresponding claims data to predict mortality and the probability of meeting target hemoglobin levels. The sensitivity, specificity, and kappa coefficient for the predialysis erythropoietin indicator were 58.0%, 78.4%, and 0.36, respectively. Patients with a predialysis erythropoietin claim were less likely to die compared with patients without a claim (odds ratio ¼ 0.80 and 95% confidence interval ¼ 0.74-0.87), but there was no relationship observed between predialysis care and death using only Form CMS-2728 predictors. At the facility level, a predialysis erythropoietin claim was associated with a 0.085 increase in the rate of meeting target hemoglobin levels compared with patients without a claim (p ¼ 0.041), but no statistically significant relationship was observed when using the Form CMS-2728 indicators. The agreement between Form CMS-2728 and claims data is poor and discordant results are observed when comparing the use of these data sources to predict health outcomes. Facilities with higher agreement between the two data sources may provide greater quality of care.

A comparison between physicians and computer algorithms for form CMS‐2728 data reporting

“…For example, one study found that there was underreporting of nursing home utilization on form 2728 . Two other studies revealed discrepancy on erythropoietin use between forms 2728 and claims data . Furthermore, inaccuracies of reported pre‐dialysis nephrology care, vascular access, and cause of ESRD for glomerular diseases were documented .…”

“…The law requires that the comorbidity section of the form needs to be completed by the nephrologist whereas other sections can be completed by support staff in the dialysis facility. Significant time, effort and extensive access to the medical record may be needed for physicians to accurately complete the 2728 form, and previous studies have confirmed that the current system of manual completion is often erroneous . Data from the previous 10 years can be used for completion, but evaluating such voluminous data from multiple Electronic Medical Records (EMR) systems is time consuming.…”

Longer-term Outcomes of Darbepoetin Alfa Versus Epoetin Alfa in Patients With ESRD Initiating Hemodialysis: A Quasi-experimental Cohort Study

“…Our sensitivity analyses of presumably ESA-naïve patients used information provided on the Medical Evidence Report, which has been shown to substantially misclassify pre-ESRD use of ESAs in two validation studies. 30 , 31 Finally, we were unable to study other ESAs, including epoetin beta, epoetin delta, epoetin omega, biosimilar epoetins, or the long-acting methoxy polyethylene glycol–epoetin beta, all of which are available in other countries, but not currently used in the United States due to patent restrictions.…”

ESRD Databases, Public Policy, and Quality of Care: Translational Medicine and Nephrology

“…Second, another issue is that data reported to the CMS may be inaccurate. Furthermore, the USRDS data derived from the Medical Evidence report submitted to the CMS are often inaccurate (30)(31)(32)(33)(34). The effects of increased use of financial incentives to improve the accuracy of dialysis facilities' self-reported data are also unclear.…”