In July 2019, the Centers for Medicare & Medicaid Services (CMS) proposed a mandatory Radiation Oncology (RO) Model that would require participation to test whether prospective site neutral, episode-based payments to physician group practices, hospital outpatient departments, and freestanding radiation therapy centers for radiotherapy episodes of care would reduce Medicare expenditures while preserving or enhancing the quality of care for Medicare beneficiaries.
The Community Oncology Alliance (COA) appreciates CMS’ commitment to increasing the number of alternative payment models (APMs) for providers to join, as APMs create opportunities for different providers to participate and succeed in unique and dynamic arrangements. However, we have significant concerns regarding the parameters of the RO model and remain staunchly opposed to mandatory Center for Medicare & Medicaid Innovation (CMMI) demonstration projects.
On September 16, 2019, we submitted formal comments to CMS about our concerns with the proposed RO model. A few specific areas we brought to their attention include the mandatory nature and scale of the model; its timing; the base rate methodology; and episode stratification and flexibility, among others.
Radiation therapy is a powerful, complex part of cancer care for patients, and the proposed CMMI RO Model does include a much-needed policy proposal to implement site-neutral payments. But we strongly affirm that no provider, nor their patients, should be forced into any transformative model. Rather, CMMI should be working closely with COA and other organizations to develop a radiation oncology model that will first test and then implement the model on a broader scale.
We appreciate CMS’ decision to issue a model focused on radiation oncology and larger efforts to transition providers out of fee-for-service arrangements and into value-based care solutions that will improve quality of care, lower costs, and enhance patient experience. The RO Model has the potential to fundamentally shift physician reimbursement and incentivize appropriate and timely care.
COA hopes to work together with the administration to ensure the final RO Model is appropriately flexible for patients and qualified providers, including community oncologists, and that it results in high-quality, low-cost care, and enhanced patient experiences for all patients included in the model.
