On July 19, the Centers for Medicare & Medicaid Services (CMS) proposed a set of modifications for the mandatory Radiation Oncology (RO) Model, as part of the Outpatient Prospective Payment System (OPPS) rule. This model is designed to improve the quality of care for cancer patients receiving radiotherapy while reducing or maintaining Medicare spending. The model is proposed to begin in January 2022 and will last five years. It was originally finalized to begin on January 1, 2021, but implementation was delayed by one year. The model consists of 30% of all radiation oncologists in the United States, including those at teaching hospitals, and mandatory participation is randomized by core-based statistical areas.
The RO Model will utilize site-neutral payments for radiotherapy services for 15 cancer types. Prospective bundled payments will be made based on a 90-day episode of care. Payment base rates will vary by cancer type, with a professional component for physician group practices and radiation oncologists, as well as a technical component for hospital outpatient departments (HOPDs) and freestanding radiotherapy centers, resulting in 30 unique base payment rates. Participants will bear 100% of the risk on the cost of radiotherapy, but costs outside of radiotherapy will be paid normally. The CMS will apply quality measures to the payment methodology, making the RO Model an Advanced Alternative Payment Model. Quality measures will include the advance care plan, plan of care for pain, depression screening and follow-up, and treatment summary communication.
The proposed rule would modify the RO Model to remove brachytherapy, remove liver cancer, and reduce the CMS discount to 3.5% for the professional component and 4.5% for the technical component (a 0.25 percentage point reduction for each). Additionally, the CMS proposed to shift the baseline period from 2016-2018 to 2017-2019, since the model has been postponed to January 2022. In terms of participant exclusions, HOPDs that are eligible for the Pennsylvania Rural Health Model (PARHM) would no longer be excluded from the RO Model unless they are participating in the PAHRM. Additionally, HOPDs participating in the Accountable Care Organizations Transformation Track of the Community Health Access and Rural Transformation (CHART) Model would also be eligible for participation in the RO Model. However, the Community Transformation Track of CHART would be excluded from the RO Model. Lastly, the RO Model would include an extreme and uncontrollable circumstances policy, which outlines the CMS’ options to provide reporting and payment flexibilities to reduce the administrative burden on providers during a declared state of emergency for natural disasters or pandemics.
The AAMC will be submitting comments on the RO Model proposed rule as part of larger comments on the OPPS rule. Comments are due by September 17, 2021.