CMS proposed the RO Model in September 2020 as a reform designed to create an alternative approach to paying for radiation therapy procedures. The agency felt that the existing reimbursement model of paying per treatment gave providers an incentive to bring patients back multiple times for radiation therapy.
With the RO Model, CMS proposed bundling payments over a single episode of care. But the agency in October 2020 delayed the start of the new payment scheme to July 2021 after the radiation oncology community asked for more time to prepare. Legislation in the Consolidated Appropriations Act of 2021 pushed that even further back, to January 2022.
In a July 19 announcement, CMS proposed additional changes to the RO Model:
- The RO Model would start on January 1, 2022, with a five-year "performance period" that would end in December 2026.
- The model's baseline period would change from 2016-2018 to 2017-2019.
- The discount for the professional component would be lowered to 3.5% and the technical component to 4.5%.
- Brachytherapy would be removed from the RO Model, and it would still be paid on a fee-for-service basis.
- Cancer inclusion criteria would be revised, and liver cancer treatments would be removed from the RO Model.
- An "extreme and uncontrollable circumstances" policy would be adopted, which would adjust the payment methodology under certain circumstances.
- Certain outpatient departments would be excluded from participation in some parts of the model.
ASTRO criticized the new CMS announcement, saying the RO Model would result in cuts of $160 million to radiation therapy services -- on top of recently proposed cuts in radiation therapy payments under the 2022 Medicare Physician Fee Schedule (MPFS).
"In two consecutive weeks, the Centers for Medicare and Medicaid Services (CMS) has singled out radiation oncology for payment cuts that put access to cancer care for Medicare beneficiaries in peril -- at a time when cancer incidence rates are rising due to delayed screenings caused by the COVID-19 pandemic," said ASTRO Chair Dr. Thomas Eichler.
Eichler called on the radiation oncology community to appeal to President Joe Biden and the U.S. Congress to reverse the RO Model and MPFS cuts.
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