Delayed Implementation of Radiation Oncology Model

The Radiation Oncology (RO) Model goals to improve the quality of care for cancer patients getting radiotherapy (RT) and move toward an easy and predictable payment system. The Radiation Oncology Model tests whether modality agnostic, bundled, site-neutral, prospective, episode-based payments to physician group practices (PGPs), hospital outpatient departments (HOPD), and freestanding radiation therapy centers for radiotherapy (RT) episodes of care decreases Medicare expenditures while preserving or increasing the quality of care for Medicare recipients. The Radiation Oncology Model has a 5-year Model performance period that begins on January 1, 2021, and runs through December 31, 2025.

CMS Announcement

CMS recently announced that it intends to delay the start of the Radiation Oncology Model after receiving feedback from stakeholders.

The CMS states in their recent announcement on October 21, “CMS has received feedback from a number of stakeholders about the challenges of preparing to implement the Radiation Oncology (RO) Model by January 1, 2021. Based on this feedback, CMS intends to delay the RO Model start date to July 1, 2021. We are pursuing rulemaking to make this change.”

The announcement is a success for radiation oncologists, who were pushing on CMS to push back the launch date for the model because of the COVID-19 pandemic.

ASTRO Response to CMS announcement

Theodore L. DeWeese, MD, FASTRO, chair of the Board of Directors at the American Society for Radiation Oncology (ASTRO) released a statement, “ASTRO appreciates today’s announcement by CMS Administrator Seema Verma that CMS will delay the Radiation Oncology Model launch from January 1, 2021, until July 1, 2021, based on feedback from ASTRO and other radiation oncology stakeholders.”

ASTRO has also shown concerns about the Radiation Oncology Model in general, including the model’s mandatory nature.

Radiation Oncology Model Covered Area

It was intended to be required for radiation therapy providers and suppliers in randomly selected core-based statistical areas starting January 1, 2021. Over 9k ZIP codes areas are participating are available on the CMS Innovation Center website.

These areas have approximately 30% of all qualified Medicare fee-for-service radiotherapy episodes nationally, which is a drop from the 40% of stakeholders criticized in the planned rule for the Model.

In comments to CMS on the final Radiation Oncology Model rule, ASTRO called required participation “untenable” for providers that are already facing issues of staff shortages. The group also said that participation in the value-based reimbursement model would require substantial practice updates and investments, which may not really be implemented in time for the January 1 start date.

The Medicare Payment Advisory Commission (MedPAC), for example, questioned the correctness of bundled payment charges under the model. The Commission said the use of hospital OPD department payment rates to identify site-neutral base bundled payments for model members would work against CMS’ goal of saving Medicare money on cancer care.

Groups including the American Hospital Association (AHA) also advised CMS to review the financial risk levels of the model, citing misaligned risk and rewards.

AHA sent a letter last week, they showed concern about the Radiation Oncology Model and asked CMS Deputy Administrator and Director Brad Smith to postpone the model’s start date until at least January 1, 2022.

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