Radiation Oncology Organization Restates Concerns About New Alternative Payment Model

Sept. 21, 2020
ASTRO says January start date is untenable for practices already enduring staff shortages and other challenges due to the pandemic

The American Society for Radiation Oncology (ASTRO) says that the advanced alternative payment model for radiation oncology practices announced last week by the Center for Medicare and Medicaid Innovation (CMMI) begins moving the specialty in the right direction but fails to address many of the radiation oncology community’s key concerns.

CMMI said the aim of the radiation oncology (RO) model is to test whether bundled, prospective, site-neutral, modality-agnostic, episode-based payments to physician group practices, hospital outpatient departments, and freestanding radiation therapy centers for radiotherapy episodes of care reduces Medicare expenditures, while preserving or enhancing the quality of care for Medicare beneficiaries. The RO Model has a five-year performance period that begins on Jan. 1, 2021 and runs through December 31, 2025.

The RO Model qualifies as an Advanced Alternative Payment Model (APM) and a MIPS APM under the Quality Payment Program. The RO Model requires RO participants to annually certify their intent to use Certified Electronic Health Record Technology (CEHRT), includes quality measure performance as a factor when determining payments, and bears more than a nominal amount of financial risk.  

ASTRO said that requiring practices to participate and then forcing them to start the model on Jan. 1, 2021, is untenable for practices already enduring staff shortages and other challenges due to the COVID-19 pandemic. “The transition to value-based payment will require significant practice changes and investments to comply with the model's requirements. ASTRO strongly urges CMS to significantly delay the start date rather than foster unnecessary chaos and burden for the practices this model is designed to support. ASTRO also will be asking Congressional leaders to delay the RO Model via legislation before the end of the year.”

In its final rule CMS did accept some of the  radiation oncology community’s recommendations to reduce the payment cuts from the initial proposal. But ASTRO said CMS should have made additional modifications. For example, mandatory participation representing 30 percent of all radiation oncology episodes, while a positive step from the 40 percent originally proposed, still goes too far for an untested model and runs counter to ASTRO’s recommendation that CMS launch the model as voluntary, then transition to a mandatory model that includes opt-outs for low-volume practices and hardship exemptions, the organization said.

ASTRO said it has worked with CMS and a bipartisan legislators for several years toward a viable payment model for radiation oncology that would support stable and fair payments, drive adherence to nationally recognized clinical guidelines and improve patient care. “We are hopeful that CMS and Congress are open to reconsidering a start date that would be realistic and not derail this unique opportunity. We also look forward to working with the agency to improve future iterations of the model to ensure that patient access to radiation therapy services is not limited."

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