ACRO Alert: Radiation Therapy APM
Wednesday, April 6, 2022
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Posted by: ACRO
The following message is from the ACRO Government Relations & Economics Committee:
On April 6, 2022, the Centers for Medicare & Medicaid Services (CMS) released a proposed rule entitled, “Radiation Oncology (RO) Model.” Within that draft regulation, CMS proposes to “delay the current start date of the RO Model to a date to be determined through future rulemaking, and to modify the definition of the model performance period to provide that the start and end dates of the model performance period for the RO Model will be established in future rulemaking.”
CMS has agreed with many ACRO proposals relating to the structure of the RO Model, including to develop a prospective (rather than retrospective) case rate, a 90-day episode, reductions in the discount factor, exclusion of brachytherapy, and other proposals. However, ACRO has continued to raise concerns in previous comments regarding the amount of the discount factor on the adequacy of case rates in the model as well as potential payment variation in the model due to proposed case mix adjustors.
While CMS notes in the proposed rule that it continues “to believe that the RO Model would address long-standing concerns related to RT delivery and payment, including the lack of site neutrality for payments, incentives that encourage volume of services over the value of services, and coding and payment challenges,” the agency further notes, “[n]o commenters agreed with the proposed discounts, and many commenters recommended that the discounts be set to 3 percent or less.” However, CMS believes that if discounts are lowered below 3.5 percent for the professional component and 4.5 percent for the technical component, the agency would need to expand the geographic scope of the RO Model to be larger than 30 percent of Core Based Statistical Areas.
As a result, CMS is proposing to delay the current start date of the RO Model, and to establish the start and end dates for the model through future rulemaking, which may also involve modifications to the model design. CMS has allowed 60 days for comment and ACRO will be commenting on the rule.
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