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Our Sustainability Accounting Standards Board (SASB) Index discloses information in alignment with SASB’s Health Care Delivery and Medical Equipment & Supplies standards. This is part of our commitment to provide transparent and relevant information on our economic, environmental, and social performance to our stakeholders. Going forward, we will continuously strive to further improve our disclosure of quantitative metrics and further enhance our SASB reporting.
Some of the information requested relates to United States requirements. For this reason, answers provided to these questions are limited to our business in the United States. In other regions, we are also subject to health care products and services standards in line with local laws and regulations.
|SASB Code||Accounting Metric||Response / Sources|
Health Care Delivery
|HC-DY-130a.1||(1) Total energy consumed, (2) percentage grid electricity, (3) percentage renewable|| |
(1) 9,323,564 GJ (2.6 million MWh)
For further information on energy management, see our Non-Financial Group Report – Energy and climate protection (pages 102 ff.).
|HC-DY-150a.1||Total amount of medical waste, percentage (a) incinerated, (b) recycled or treated, and (c) landfilled||In 2022, we continued to analyze the waste streams of our production sites and dialysis clinics in all regions. As part of this process, we implemented waste reporting processes at our production sites. Furthermore, we are working to consolidate the data on waste generation gathered in our dialysis clinics by identifying data sources and improving reporting methodologies. We plan to disclose waste data in our non-financial reporting for 2023. For further information on our waste management activities, see our Non-Financial Group Report – Waste (page 104 f.).|
|HC-DY-150a.2||Total amount of: (1) hazardous and (2) nonhazardous pharmaceutical waste, percentage (a) incinerated, (b) recycled or treated, and (c) landfilled|
|Patient Privacy & Electronic Health Records|
|HC-DY-230a.1||Percentage of patient records that are Electronic Health Records (EHR) that meet "meaningful use" requirements||Only practitioners employed or contracted in medical practices owned or operated by Fresenius Medical Care in North America are eligible to participate in the “meaningful use/promoting interoperability” incentive programs. The other health care services delivery businesses (e.g., dialysis facilities, ambulatory surgery centers, etc.) are not eligible to participate. An affiliate subsidiary company of Fresenius Medical Care in North America, Acumen Physician Solutions, LLC (which transferred to InterWell Health in September 2022, and Fresenius Medical Care has a significant interest in InterWell Health), offers a "meaningful use" EHR software (utilizing Epic Systems) as a service that is available to both affiliated and unaffiliated nephrology practices.|
|HC-DY-230a.2||Description of policies and practices to secure customers’ protected health information (PHI) records and other personally identifiable information (PII)|| |
For a description of policies and practices related to securing our patients’ health information and further data, see our Non-Financial Group Report – Protecting data (pages 108 f.). See our Notice of Privacy Practices for a description of how medical information is used and disclosed in the United States.
|HC-DY-230a.3||(1) Number of data breaches, (2) percentage involving (a) personally identifiable information (PII) only and (b) protected health information (PHI), (3) number of customers affected in each category, (a) PII only and (b) PHI||In 2022, the U.S. business identified 54 data breaches, as defined by applicable state and federal law. These breaches affected PHI (Personal Health Information). Besides, there were no reportable breaches affecting PII (Personal Identifiable Information).|
|HC-DY-230a.4||Total amount of monetary losses as a result of legal proceedings associated with data security and privacy|| |
Fresenius Medical Care did not incur monetary losses in the United States during the reporting period as a result of legal proceedings associated with data security and privacy, meaning adjudicative proceedings before a court, regulator, arbitrator or otherwise. All relevant legal proceedings and related financial effects are disclosed in our Annual Report – Notes to the Consolidated Financial Statements.All relevant legal proceedings and related financial effects are disclosed in our Annual Report – Notes to the consolidated financial statements (pages 257 ff.).
|Access for Low-Income Patients|
|HC-DY-240a.1||Discussion of strategy to manage the mix of patient insurance status||In our dialysis clinics, we treat patients with all kinds of insurance status. In the United States, the insurance mix includes the federal health insurance programs Medicare and Medicaid, as well as private/alternative payors such as commercial insurance and private funds. For information on our efforts to expand access to high-quality care for more patients, see our Non-Financial Group Report – Access to health care (pages 91 f.).|
|HC-DY-240a.2||Amount of Medicare Disproportionate Share Hospital (DSH) adjustment payments received||Not applicable.|
|Quality of Care & Patient Satisfaction|
|HC-DY-250a.1||Average Hospital Value-Based Purchasing Total Performance Score and domain score, across all facilities||We do not operate acute care hospitals in the United States. Consequently, this indicator is not relevant for us. For general information on quality of care and patient satisfaction, see our Non-Financial Group Report – Quality of care (pages 90 ff.).|
|HC-DY-250a.2||Number of Serious Reportable Events (SREs) as defined by the National Quality Forum (NQF)||We do not report this data. For information on quality of care and patient satisfaction, see our Non-Financial Group Report – Quality of care (pages 90 ff.).|
|HC-DY-250a.3||Hospital-Acquired Condition (HAC) Score per hospital||We do not operate acute care hospitals in the United States. Consequently, this indicator is not relevant for us.|
|HC-DY-250a.4||Excess readmission ratio per hospital||We do not operate acute care hospitals in the United States. Consequently, this indicator is not relevant for us.|
|HC-DY-250a.5||Magnitude of readmissions payment adjustment as part of the Hospital Readmissions Reduction Program (HRRP)||We do not operate acute care hospitals in the United States. Consequently, this indicator is not relevant for us.|
|Management of Controlled Substances|
|HC-DY-260a.1||Description of policies and practices to manage the number of prescriptions issued for controlled substances|| |
The United States dialysis services business does not permit controlled substances to be kept or administered in its outpatient dialysis units. Dialysis facility staff do not prescribe controlled substances.
In the dialysis services business in other parts of the world where controlled substances are permitted, we have established specific protocols to ensure the safe handling and storage of these medications. In those locations we ensure that the appropriate level staff is trained on the appropriate use, storage, and disposal of controlled substances as required by local/regional laws. Similarly, staff supports patients with substance abuse disorders where required by local/regional laws.
|HC-DY-260a.2||Percentage of controlled substance prescriptions written for which a prescription drug monitoring program (PDMP) database was queried||Not applicable to the United States dialysis services business.|
|Pricing & Billing Transparency|
|HC-DY-270a.1||Description of policies or initiatives to ensure that patients are adequately informed about price before undergoing a procedure|| |
The dialysis services business follows the local laws and requirements governing pricing disclosures. The method of communication varies by country and includes written communication, website posting, and in-person consultation, as required.
We work with the insurer/payor to understand the patient’s responsibility. For self-pay, we work directly with the patient to provide estimates for what they will be responsible for.The United States dialysis services business has two approaches. For insured patients, the business first submits a claim to the insurance provider. The insurance provider informs the business about what the patient is responsible for based on their plan. In the case of self-pay patients, the business can provide an estimate of price. For the dialysis services business outside of the United States, the company follows the pricing requirements outlined by the national health system in that country.
|HC-DY-270a.2||Discussion of how pricing information for services is made publicly available||For outpatient services in the United States, the Company sets our pricing and certain pricing information is made publicly available where required by price transparency laws. Pricing for dialysis services outside the United States is usually subject to local law and reimbursements. For more information on reimbursements, see our form 20-F (pages 51 ff.).|
|HC-DY-270a.3||Number of the entity’s 25 most common services for which pricing information is publicly available, percentage of total services performed (by volume) that these represent|
|Employee Health & Safety|
|HC-DY-320a.1||(1) Total recordable incident rate (TRIR) and (2) days away, restricted, or transferred (DART) rate|| |
(1) For the total recordable incident rate, see our ESG Performance Data – Occupational health and safety (page 9).(2) We do not report the days away, restricted, or transferred (DART) rate. For further information on employee health and safety, see our Non-Financial Group Report – Occupational health and safety (page 100).
|Employee Recruitment, Development & Retention|
|HC-DY-330a.1||(1) Voluntary and (2) involuntary turnover rate for: (a) physicians, (b) non-physician health care practitioners, and (c) all other employees||For 2022, our total voluntary turnover rate is 19.9%, and our total involuntary turnover rate is 5.7%. For employees based in the United States, representing approximately 50% of total employees globally, the voluntary turnover rate for physicians is 11.8% and the involuntary turnover rate is 2.1%. For non-physician health care practitioners, the voluntary turnover rate is 24.1% and the involuntary turnover rate is 3.5%. For further information on voluntary and involuntary turnover rates, see our ESG Performance Data – Talent management (pages 7 f.) and our Non-Financial Group Report – Employees worldwide (pages 96 f.).|
|HC-DY-330a.2||Description of talent recruitment and retention efforts for health care practitioners|| |
For information on nurses training programs, global career paths, and insights into the jobs of our clinical staff, see our Nephrocare website, our corporate website, and our career website in the United States.
|Climate Change Impacts on Human Health & Infrastructure|
|HC-DY-450a.1||Description of policies and practices to address: (1) the physical risks due to an increased frequency and intensity of extreme weather events and (2) changes in the morbidity and mortality rates of illnesses and diseases, associated with climate change||We have dialysis clinics in many regions of the world with diverse geographic, social, and economic conditions, serving a vulnerable population of patients who need regular dialysis treatment multiple times a week. To allow us to continue treating our patients in extreme conditions, we have developed an emergency response system comprising regional disaster response teams. For further information on our disaster response activities, see our Risk and Opportunities Report – Unpredictable events (page 72) and our Non-Financial Group Report – Crisis and emergency response (pages 92 f.). Additionally, take a look at the disaster relief fact sheet and our website communication on disaster response in emergencies.|
|HC-DY-450a.2||Percentage of health care facilities that comply with the Centers for Medicare and Medicaid Services (CMS) Emergency Preparedness Rule||The United States services business (including FKC, Azura, and NCP) has policies and procedures that have been adopted by 100% of its outpatient facilities, consistent with the CMS Emergency Preparedness Rule.|
|Fraud & Unnecessary Procedures|
|HC-DY-510a.1||Total amount of monetary losses as a result of legal proceedings associated with Medicare and Medicaid fraud under the False Claims Act||The United States business did not sustain any monetary losses as a result of such proceedings during the reporting period.|
Medical Equipment and Supplies
|Affordability & Pricing|
|HC-MS-240a.1||Ratio of weighted average rate of net price increases (for all products) to the annual increase in the U.S. Consumer Price Index||The business makes certain pricing information publicly available where required by price transparency laws. Pricing is usually subject to local law and reimbursements.|
|HC-MS-240a.2||Description of how price information for each product is disclosed to customers or to their agents|
|HC-MS-250a.1||Number of recalls issued, total units recalled||In the United States, there were nine recalls of drugs and devices in 2022 in the form of removals, corrections, or alerts. |
In non-U.S. markets, there were two recalls of medical devices and no recalls of medicinal products in 2022. Products of Fresenius Medical Care Nephrologica Deutschland GmbH are not in scope.
|HC-MS-250a.2||List of products listed in the FDA’s MedWatch Safety Alerts for Human Medical Products database||We do not report this data. For information on product safety and quality, see our Non-Financial Group Report – Product stewardship (pages 94 f.).|
|HC-MS-250a.3||Number of fatalities related to products as reported in the FDA Manufacturer and User Facility Device Experience database||No fatalities have been reported in which a causal relationship with our products has been definitively established.|
|HC-MS-250a.4||Number of FDA enforcement actions taken in response to violations of current Good Manufacturing Practices (cGMP), by type||In 2022, no FDA 483 forms were issued to sites owned or operated by Fresenius Medical Care North America. In addition, there were no FDA enforcement actions such as warning letters, seizures, and consent decrees against sites owned or operated by Fresenius Medical Care North America.|
|HC-MS-270a.1||Total amount of monetary losses as a result of legal proceedings associated with false marketing claims||All relevant legal proceedings and related financial effects are disclosed in our Annual Report – Notes to the consolidated financial statements (pages 257 ff.). None of such legal proceedings was associated with false marketing claims which resulted in monetary losses.|
|HC-MS-270a.2||Description of code of ethics governing promotion of off-label use of products||Our Code of Ethics and Business Conduct outlines our commitment to always be truthful, accurate, and not misleading when promoting our products and services. For further information on advertising and promotion, see our Code of Ethics and Business Conduct – Advertising and promotion (page 22).|
|Product Design & Lifecycle Management|
|HC-MS-410a.1||Discussion of process to assess and manage environmental and human health considerations associated with chemicals in products, and meet demand for sustainable products|| |
It is essential that our products and services are effective and reliable, and that they pose as little risk as possible to patients. Our standards for planning, conducting, and monitoring clinical studies help us enhance the quality and safety of our products. For further information on the safety of our products, see our Non-Financial Group Report – Product stewardship (pages 94 f.).
To help us understand the environmental impact of our products, we conduct simplified product life-cycle assessments for selected products. These assessments identify the life-cycle phase with the highest impact and the processes and materials we need to focus on to improve the eco-performance of our products and services. For further information on our life cycle assessments, see our Non-Financial Group Report – Eco-performance of products and services (page 105). In 2021, we initiated a process to further integrate specific environmental criteria in our research and development activities. In 2022, we launched a global event aimed at fostering innovation in our product business. As part of this activity, employees were encouraged to develop new ideas that focused on the topics of sustainability and efficiency. For further information on research and development, see our Non-Financial Group Report – Innovation and digitalization (pages 93 f.).
|HC-MS-410a.2||Total amount of products accepted for take-back and reused, recycled, or donated, broken down by: (1) devices and equipment and (2) supplies|| |
We donate funds, dialysis machines, and medical supplies to organizations that require support. In our global survey on corporate citizenship activities, it was reported that we donated around 1.5 metric tons of devices and equipment reflecting a total value of around 44,000 €. We also donated more than 43 metric tons of supplies reflecting a total value of around 1,857,000 €. In addition, we donated devices, equipment, and supplies with a monetary value of more than 300,000 € to support patients and employees in Ukraine.For further information on waste reduction initiatives, see our Non-Financial Group Report – Waste (pages 104 f.).
|Supply Chain Management|
|HC-MS-430a.1||Percentage of (1) entity's facilities and (2) Tier I suppliers' facilities participating in third-party audit programs for manufacturing and product quality||Not applicable.|
|HC-MS-430a.2||Description of efforts to maintain traceability within the distribution chain||We are analyzing the environmental and social impact associated with our supply chain. For further information on our supply chain management, see our Non-Financial Group Report – Supplier management (pages 109 f.).|
|HC-MS-430a.3||Description of the management of risks associated with the use of critical materials|| |
Sourcing of mineral raw materials is an important aspect of our commitment to sustainable procurement.
We are subject to the provisions of Section 1502 of the U.S. Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) relating to conflict minerals. As outlined in our Conflict Minerals Policy, we adopt standards in line with the Organization for Economic Co-operation and Development’s (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.
We are committed to compliance with Section 1502 of the Dodd-Frank Act and encourage our suppliers to foster similar commitments of their supply chain related to conflict minerals disclosures. Suppliers who are non-compliant with our Conflict Minerals Policy are reviewed for continued business.For additional information on this topic, see our corporate supply chain website. On this website, you find a statement on responsible minerals sourcing as well as our annual Conflict Minerals Report.
|HC-MS-510a.1||Total amount of monetary losses as a result of legal proceedings associated with bribery or corruption||We did not have monetary losses associated with formal legal proceedings associated with bribery or corruption in 2022. All relevant legal proceedings and related financial effects are disclosed in our Annual Report – Notes to the consolidated financial statements (pages 257 ff.).|
|HC-MS-510a.2||Description of code of ethics governing interactions with health care professionals||We have a Code of Ethics and Business Conduct that covers general compliance concepts and standards, including the expectation that all employees perform their duties in accordance with the Company’s purpose, global values, policy, the Code of Ethics and Business Conduct, and the law. The general principles in the Code of Ethics and Business Conduct are supported by policies that address specific situations in accordance with all applicable local laws, including interactions with health care professionals.|