Kidney Care Choices (KCC) is the CMS Innovation Center's flagship value-based kidney care model, and the most operationally significant CMMI specialty model for late-stage chronic kidney disease (CKD) and end-stage renal disease (ESRD) populations. KCC creates an accountable payment framework that spans the entire kidney care continuum: late-stage CKD (Stages 4-5), ESRD on dialysis, and the first three years post-kidney-transplant. The model is the direct successor to the Comprehensive ESRD Care (CEC) Model and the operational vehicle for implementing the Advancing American Kidney Health Initiative (Executive Order 13879, July 10, 2019), which set goals to reduce ESRD incidence, expand home dialysis adoption, and increase kidney transplant availability.
For Georgia, a state with substantial ESRD burden concentrated in metro Atlanta, Macon, Augusta, Columbus, and Savannah, and with hundreds of dialysis facilities operated primarily by Davita and Fresenius, KCC represents the most direct value-based reform applied to kidney care. This guide explains how KCC works, who participates, how payment flows, what KCC means for Georgia clinicians and beneficiaries, and how KCC relates to other CMMI models and the parallel ESRD Treatment Choices (ETC) Model.
- KCC operates over a five-year performance period (Performance Years 2022 through 2026)
- Two tracks: Kidney Care First (KCF) for smaller nephrology practices; Comprehensive Kidney Care Contracting (CKCC) for larger entities with three risk options (Graduated, Professional, Global)
- Serves Medicare FFS beneficiaries with late-stage CKD (Stages 4-5), ESRD on dialysis, and kidney transplant recipients in their first three post-transplant years
- KCC qualifies as an Advanced APM, enabling participating clinicians to achieve Qualifying APM Participant (QP) status and MIPS exemption
- The parallel ETC Model is a separate mandatory CMMI model affecting payment in randomly selected Hospital Referral Regions, including some Georgia regions
The statutory and regulatory foundation
KCC rests on overlapping statutory and policy authorities:
- Section 1115A of the Social Security Act: the CMS Innovation Center statutory framework, added by the Affordable Care Act. KCC operates as a CMMI demonstration under Section 1115A authority.
- Executive Order 13879, Advancing American Kidney Health (July 10, 2019). EO 13879 established goals to reduce ESRD incidence, increase home dialysis adoption among new ESRD patients, and expand kidney transplant availability.
- Section 1833(z) SSA: the Advanced APM and QP framework added by MACRA. KCC is structured as an Advanced APM.
- CMMI Kidney Care Choices Request for Applications (2019): the original KCC model RFA.
- KCC Participation Agreements: legal contracts between CMS and participating entities for each track.
The parallel ESRD Treatment Choices (ETC) Model is a separate but related mandatory model that adjusts dialysis facility and managing clinician payments based on home dialysis and transplant rates. KCC is voluntary; ETC is mandatory for facilities and clinicians in randomly selected Hospital Referral Regions, including some Georgia regions.
The KCC performance period
KCC operates over a five-year performance period covering Performance Years 2022 through 2026. Future kidney care models, if any, would succeed KCC under separate CMMI authority.
The KCC two-track design
KCC has two main tracks designed for different practice scales:
Kidney Care First (KCF)
KCF is designed for smaller nephrology practices that want a more streamlined participation pathway. Under KCF:
- Adjusted Monthly Capitation Payment (AMCP): capitated payment for nephrology professional services for late-stage CKD and ESRD beneficiaries (replaces the monthly capitation payment MCP for ESRD nephrology)
- Per-Beneficiary Per-Month (PBPM) Care Coordination Payments: for late-stage CKD and ESRD beneficiaries
- Performance-Based Adjustment: quality-based adjustment on top of AMCP and care coordination payments
- No total cost of care risk: KCF practices do not assume risk for total Medicare spending on attributed beneficiaries
- Bonus payments: home dialysis bonus, kidney transplant bonus, and other incentive payments
KCF is appropriate for nephrology practices that want value-based participation without the complexity of total cost of care risk.
Comprehensive Kidney Care Contracting (CKCC)
CKCC is the more advanced track designed for larger entities, typically nephrology groups or kidney care companies, that bring together nephrologists, dialysis facilities, transplant providers, and other care team members into accountable arrangements. CKCC entities accept total cost of care accountability for attributed beneficiaries.
CKCC has three risk options:
CKCC Graduated
- Lower risk option
- One-sided risk in early performance years
- Two-sided risk in later years
- Shared savings/losses capped at lower rates
- Designed for entities new to global risk
CKCC Professional
- Two-sided risk from start
- Professional services bundle accountability
- Shared savings and losses at moderate rates (modified by performance)
- Designed for entities with two-sided risk experience
CKCC Global
- Full two-sided risk
- Highest share of shared savings and losses
- Highest reward / highest exposure
- Designed for entities with strong infrastructure and analytical capacity
- Most analogous to ACO REACH Global track in kidney care
CKCC entities receive the same KCF payment streams (AMCP for nephrology, care coordination payments) plus total cost of care reconciliation based on the chosen risk option.
The KCC beneficiary population
KCC's beneficiary population spans three groups across the kidney care continuum:
CKD Stages 4-5 (pre-dialysis)
- Medicare FFS beneficiaries with late-stage CKD
- Attributed to nephrologists via voluntary alignment or claims-based attribution
- Care coordination and capitated payments fund pre-dialysis education, vascular access planning, and transplant referrals
ESRD on dialysis
- Medicare FFS beneficiaries on chronic dialysis (in-center hemodialysis or home dialysis)
- Attributed via voluntary alignment or claims-based attribution to the managing nephrologist
- Care coordination payments include dialysis-related coordination
- Home dialysis modalities (home hemodialysis and peritoneal dialysis) carry incentives
Kidney transplant recipients (first 3 years post-transplant)
- Medicare FFS beneficiaries who received a kidney transplant in the past 3 years
- Attributed via voluntary alignment or claims-based attribution
- Care coordination payments support post-transplant management
- Encourages KCC entities to invest in transplant pursuit
The KCC payment architecture
KCC payment combines multiple streams:
Adjusted Monthly Capitation Payment (AMCP)
- Capitated nephrology professional services payment
- Replaces traditional Monthly Capitation Payment (MCP) for ESRD nephrology
- Higher payment for home dialysis modalities (home hemodialysis and peritoneal dialysis), building in a home dialysis incentive
- Adjusted by risk and visit patterns
Per-Beneficiary Per-Month (PBPM) Care Coordination Payments
- Late-stage CKD PBPM payment
- ESRD PBPM payment
- Transplant PBPM payment (first 3 years post-transplant)
- Fund care management infrastructure, vascular access planning, transplant referrals, social work, dietician services
Kidney Transplant Bonus
- One-time bonus when an attributed CKD or ESRD beneficiary receives a kidney transplant
- Encourages KCC entities to invest in transplant workups, evaluations, and referrals
- Direct alignment with EO 13879 transplant goals
Home Dialysis Bonus
- Incremental payment for home dialysis modalities
- Built into AMCP structure (higher AMCP for home dialysis)
- Plus additional CKCC home dialysis incentives in some cases
- Direct alignment with EO 13879 home dialysis goals
Performance-Based Adjustment (KCF)
- Quality-based adjustment on top of capitated payments
- Quality measures aligned with ACO quality set (see below)
Total Cost of Care Reconciliation (CKCC)
- Annual reconciliation of total Medicare Part A and Part B spending for attributed beneficiaries
- Compared to benchmark
- Savings or losses shared with CKCC entity based on risk option
The KCC quality measures
KCC measures performance on a focused set of quality measures aligned with the broader ACO quality framework:
- CAHPS for ACOs / KCC: patient experience survey
- Risk-Standardized Hospital Admission Rates: practice-level hospital admission rate adjusted for risk
- Diabetes HbA1c Poor Control: eCQM for diabetic beneficiaries
- Optimal ESRD Starts: preparation for renal replacement therapy (vascular access, planned dialysis start)
- Depression Screening / Other ACO-Aligned Measures: varies across performance years
Performance on these measures drives the Performance-Based Adjustment in KCF and quality-adjusted reconciliation in CKCC.
Advanced APM status and the Quality Payment Program
KCC is structured as an Advanced APM under Section 1833(z) SSA. KCC satisfies the three Advanced APM criteria:
- CEHRT use: participating entities use certified EHR technology
- Quality measurement: KCC quality measures comparable to MIPS
- Risk-bearing: meaningful risk via Performance-Based Adjustment (KCF) or total cost of care risk (CKCC)
Advanced APM status drives Qualifying APM Participant (QP) determination. KCC clinicians who meet QP or Partial QP thresholds receive:
- MIPS exemption
- APM Incentive Payment (amount varies by performance year per QPP policy)
- Qualifying APM Conversion Factor differential in later performance years
Partial QPs may elect MIPS via APP; non-QP MIPS-eligible KCC clinicians use APP.
Beneficiary attribution
KCC beneficiaries are attributed via:
Voluntary alignment
- Beneficiary self-attestation
- Submitted via MyMedicare.gov
- Available for late-stage CKD, ESRD, and post-transplant beneficiaries
Claims-based attribution
- Plurality of nephrology services
- Recalculated periodically
- Default attribution method
Beneficiaries retain all Medicare FFS rights: freedom of choice of provider, no enrollment, no cost, no benefit changes.
The ESRD Treatment Choices (ETC) Model: the parallel mandatory model
ETC is a separate but related CMMI model that affects payment for managing clinicians and dialysis facilities in randomly selected Hospital Referral Regions (HRRs). ETC is mandatory for facilities and clinicians located in selected HRRs.
ETC mechanics:
- Adjusts payment to managing clinicians and dialysis facilities based on home dialysis and transplant rates
- Home Dialysis Payment Adjustment (HDPA)
- Performance Payment Adjustment (PPA)
- Selected HRRs include some Georgia regions
A Georgia nephrologist may participate in KCC (voluntary) and simultaneously be subject to ETC (mandatory) if located in a selected HRR. The two models can coexist with payment effects calculated independently.
Georgia kidney care landscape
Georgia has substantial ESRD and late-stage CKD populations:
Major dialysis providers
- Davita: largest Georgia dialysis network, dozens of facilities across the state
- Fresenius Medical Care: second-largest Georgia network, dozens of facilities
- Smaller independent dialysis providers: limited presence
Integrated system kidney programs
- Emory Healthcare: kidney program including transplant center
- Wellstar Health System: kidney program
- Piedmont Healthcare: kidney program
- Augusta University Health: kidney program in Augusta
Transplant centers
- Emory Transplant Center: major Georgia kidney transplant program
- Piedmont Transplant Institute: major Georgia transplant program
- Augusta University Transplant: Augusta-area transplant program
KCC participation
- Selected Georgia nephrology practices and KCC entities participate in KCF and CKCC tracks
- Some integrated system kidney programs participate in CKCC arrangements
- Specific participant lists are CMS-maintained; beneficiaries can ask their nephrologist directly
ESRD Network
- ESRD Network 6 (Georgia, North Carolina, South Carolina): federally designated ESRD Network for Georgia
- Provides patient grievance, quality improvement, and emergency preparedness functions
14 best practices for KCC participants
- Strong vascular access planning: pre-dialysis fistula/graft creation drives Optimal ESRD Starts measure
- Aggressive transplant referrals: earlier transplant workups improve outcomes and trigger Kidney Transplant Bonus
- Home dialysis modality counseling: match patient preferences with feasibility; home dialysis carries higher AMCP and bonuses
- Care management infrastructure: fund care managers, social workers, dieticians with PBPM payments
- Risk stratification: identify high-risk beneficiaries for intensive intervention
- CKD education: early CKD education improves modality choice and reduces crashed starts
- Vascular access surveillance: monitor and maintain vascular access for in-center dialysis patients
- Transplant center collaboration: close partnerships with transplant centers facilitate transplant pursuit
- Post-transplant management: strong post-transplant infrastructure for first three years
- Medication management: immunosuppression for transplant recipients, ESA and phosphate binders for ESRD
- Acute care coordination: reduce hospital admissions through proactive management
- Skilled nursing facility coordination: many ESRD patients require SNF stays; strong SNF coordination matters
- Behavioral health integration: depression is common in ESRD; integrated screening and treatment
- APP reporting (for non-QP clinicians): non-QP MIPS-eligible KCC clinicians must submit APP at the APM Entity level
14 common KCC issues
- AMCP confusion with traditional MCP: billing system reconfiguration required
- Home dialysis underutilization: without practice investment, home dialysis adoption stays low and bonuses are missed
- Transplant pursuit underinvestment: small practices struggle to invest in transplant workups
- CKCC risk option mismatch: entities that select Global without adequate infrastructure face large losses
- Quality measure data completeness: eCQM extraction issues impair PBA
- Attribution churn: beneficiaries moving between nephrology practices create attribution complexity
- ETC overlay confusion: KCC and ETC can both apply; payment effects calculated independently
- Vascular access timing: late vascular access planning hurts Optimal ESRD Starts measure
- Transplant center bottlenecks: transplant evaluation waitlists slow transplant pursuit
- Hospitalization spikes: high-risk ESRD beneficiaries drive hospital costs, hurting CKCC reconciliation
- Dialysis facility coordination: KCC entities and dialysis facilities (often Davita/Fresenius) require strong coordination
- Risk stratification gaps: practices that do not actively identify highest-risk beneficiaries miss intervention opportunities
- QP threshold tracking: practices unaware of QP determination may miss QP status
- Performance Year transitions: payment, quality, and attribution rules can change between PYs
Six worked examples: Georgia Medicare beneficiaries in KCC
1. Fulton 70: Atlanta KCC late-stage CKD
A 70-year-old Atlanta beneficiary with CKD Stage 4 is attributed to an Atlanta nephrology practice participating in KCC KCF. The practice receives late-stage CKD AMCP and PBPM care coordination payments. Care management includes pre-dialysis education, transplant referral to Emory Transplant Center, and vascular access planning. If she progresses to ESRD and starts dialysis with a planned vascular access, the practice earns Optimal ESRD Starts credit on its quality measure.
2. DeKalb 75: DeKalb ESRD in-center hemodialysis
A 75-year-old DeKalb beneficiary on in-center hemodialysis at a Davita facility three times per week is attributed via claims-based attribution to her managing nephrologist who participates in KCC CKCC Professional Risk. The CKCC entity receives ESRD AMCP, PBPM care coordination payments, and is accountable for total Medicare cost of care. The entity invests in care coordination, behavioral health screening, and SNF transitions to reduce hospital utilization.
3. Cobb 68: Cobb home peritoneal dialysis
A 68-year-old Cobb beneficiary on home peritoneal dialysis is attributed to a Cobb nephrology practice in KCC KCF. The practice receives the higher home dialysis AMCP rate and PBPM care coordination payments. Investment in home dialysis training and ongoing patient support pays off in the form of higher AMCP and home dialysis incentives.
4. Worth County 72: Albany rural ESRD
A 72-year-old Worth County rural ESRD beneficiary on in-center hemodialysis at an Albany-area Fresenius facility is attributed to an Albany-area nephrology practice. KCC enables the practice to invest in transportation coordination and rural care management resources funded by PBPM care coordination payments. ETC may also apply if the Albany HRR is in the ETC mandatory selection.
5. Bibb 80: Macon post-transplant
An 80-year-old Bibb beneficiary received a kidney transplant 14 months ago at Piedmont Transplant Institute and is now in her second post-transplant year. She is attributed to a Macon nephrology practice participating in KCC. The practice receives transplant PBPM care coordination payments funding post-transplant management, immunosuppression monitoring, and rejection surveillance. The practice's earlier work referring her to transplant earned the Kidney Transplant Bonus at the time of transplant.
6. Hall 67: Gainesville CKCC Global
A 67-year-old Hall County beneficiary with CKD Stage 5 approaching dialysis is attributed via voluntary alignment to a Gainesville nephrology entity participating in KCC CKCC Global Risk. The CKCC Global entity accepts full two-sided total cost of care risk on her future care. The entity invests heavily in her pre-dialysis preparation: home dialysis education, vascular access planning, transplant referral, and intensive care management. Whether her ESRD onset is smooth (planned home dialysis, transplant pursuit) or rough (crashed start, prolonged hospitalization) directly affects the entity's CKCC reconciliation.
Frequently asked questions
What is Kidney Care Choices (KCC)?
KCC is a CMS Innovation Center value-based kidney care model with two tracks (KCF and CKCC) that operates over a five-year performance period and serves Medicare FFS beneficiaries with late-stage CKD, ESRD on dialysis, and post-transplant in the first three years.
Who is eligible for KCC?
Medicare FFS beneficiaries with late-stage CKD (Stages 4-5), ESRD on chronic dialysis, or kidney transplant recipients in the first three years post-transplant. Beneficiaries do not enroll; attribution is via voluntary alignment or claims-based attribution with no additional cost or benefit changes.
What are the two KCC tracks?
Kidney Care First (KCF) is for smaller practices, providing capitated payment plus care coordination without total cost of care risk. Comprehensive Kidney Care Contracting (CKCC) is for larger entities with three risk options (Graduated, Professional, Global) and total cost of care accountability.
Is KCC an Advanced APM?
Yes. KCC satisfies the three Advanced APM criteria (CEHRT use, quality measurement, and meaningful risk) and qualifies participating clinicians for QP determination, MIPS exemption, and APM incentive payments.
How does KCC relate to the ETC Model?
ETC is a separate mandatory CMMI model that adjusts payment to managing clinicians and dialysis facilities in randomly selected HRRs based on home dialysis and transplant rates. KCC is voluntary; ETC is mandatory. Georgia nephrologists in ETC-selected HRRs may be subject to both models simultaneously, with payment effects calculated independently.
Contact resources
Federal Medicare resources
- Medicare (general): 1-800-MEDICARE (1-800-633-4227)
- CMS Innovation Center: innovation.cms.gov
- QPP Service Center: 1-866-288-8292
- Palmetto GBA (Part A/B MAC Jurisdiction J): 1-866-238-9650
Georgia kidney care resources
- ESRD Network 6 (GA, NC, SC): 1-919-855-0882 (federally designated ESRD Network for Georgia)
- National Kidney Foundation: 1-855-653-2273
- American Kidney Fund: 1-866-300-2900
Georgia state resources
- GeorgiaCares SHIP: 1-866-552-4464 (free Medicare counseling)
- 211 Georgia: 2-1-1
- Georgia Department of Community Health: dch.georgia.gov
- Georgia Aging and Disability Resource Connection: 1-866-552-4464
Beneficiary advocacy
- Medicare Rights Center: 1-800-333-4114
- Eldercare Locator: 1-800-677-1116
- Atlanta Legal Aid: 404-377-0701
- Georgia Legal Services: 1-800-498-9469
- Acentra Health QIO: 1-844-455-8708
Federal benefit administration
- Social Security Administration: 1-800-772-1213
- Benefits Coordination & Recovery Center (BCRC): 1-855-798-2627
Why KCC matters
KCC is the most concrete value-based kidney care reform in Medicare today. By creating an accountable framework spanning the entire kidney care continuum, KCC fundamentally restructures how nephrologists and kidney care entities are paid. The model's home dialysis and transplant incentives operationalize the Advancing American Kidney Health Initiative's policy goals. Its Advanced APM status integrates kidney care into the QPP framework, qualifying participating clinicians for QP determination and MIPS exemption. For Georgia, a state with substantial ESRD burden, large Davita and Fresenius dialysis networks, and growing transplant programs at Emory and Piedmont, KCC represents the most significant payment reform applied to kidney care in a generation. Whether through the simpler KCF track or the full-risk CKCC Global option, KCC is reshaping how Medicare pays for kidney care in Georgia and across the country.
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