CMS Seeks Changes to Radiation Oncology Model; ASTRO Responds

Once again, the Radiation Oncology (RO) Model is the subject of proposed changes under CMS’ annual Medicare Hospital Outpatient Prospective Payment System (HOPPS) and Ambulatory Surgical Center (ASC) Payment System rulemaking. For several years, CMS has proposed a model that would test whether making site-neutral payments to physician practices, including free-standing radiation therapy centers, would “preserve or enhance” care quality while reducing Medicare spending.

However, the head of the organization representing radiation oncologists criticized CMS’ plans; Thomas J. Eichler, MD, chair of American Society for Radiation Oncology (ASTRO), declared, “Access to radiation therapy for people with cancer is under attack.”

The RO Model has been discussed since 2014. ASTRO has said it agrees with the concept of value-based care but has disagreed with CMS on reimbursement levels and whether to make the model mandatory. Then, in the wake of unprecedented disruption and missed screenings due to the pandemic, efforts to implement a 5-year performance period under the RO Model were extended: first under the 2021 interim final rule and again under the Consolidated Appropriations Act, 2021. The appropriations act delayed the start of the RO Model until January 1, 2022.

On Monday, CMS’ proposal for the 2022 Medicare HOPPS and ASC Payment System Rule addressed a number of areas that have been affected by the COVID-19 public health emergency, including the RO Model. According to a summary from CMS, the proposed 2022 rulemaking puts forth the following:

• The 5-year performance period would begin on January 1, 2022, and end on December 31, 2026
• The baseline period would shift from 2016-2018 to 2017-2019.
• Discounts would be lowered to 3.5% for the Professional Component and 4.5% for the Technical Component
• Brachytherapy would be removed from the list of modalities under the RO Model; it would be paid under fee-for-service
• Cancer inclusion criteria would be revised, and liver cancer would not meet the criteria for the model
• If a beneficiary switches from Medicare to Medicare Advantage during an episode before treatment is complete, CMS would deem the episode incomplete, and radiation therapy would be paid the traditional Medicare rate
• CMS would adopt an “extreme and uncontrollable circumstances” policy, which would offer flexibility to limit reporting and other administrative burdens of RO Model participation; payment would be adjusted as necessary

In its proposal, CMS calls for excluding hospital outpatient departments that are taking part in the Community Transformation track of the CHART Model from participation in the RO Model. In these cases, the same policy for overlap between the RO Model and the Medicare Shared Savings Program would apply.

In his statement, ASTRO’s Eichler asked why CMS has “singled out” radiation oncology for payment cuts when cancer incidence rates are rising, following the delayed screenings seen during COVID-19.

“By proposing to cut high-value radiation treatments by as much as 22% and proceeding with more than $160 million in reductions under the RO Model, CMS is jeopardizing the ability of the nation’s radiation therapy professionals to continue to provide essential care for their patients now and in the future,” he said. “Access to life-saving cancer treatments will suffer, and the viability of clinics already reeling from the pandemic will be at considerable risk if these proposals are finalized.”

ASTRO called on President Joe Biden, given his history of advocacy for patients with cancer, to intervene in changing the RO Model proposals and other Medicare Physician Fee Schedule cuts. Eichler said the group would once again appeal to Congress for direct relief if its plea to the administration is not successful.

The radiation oncologists, he said, are “committed to value-based care and to constructively engaging with CMS on reasonable ways to improve these policies. We are eager to help President Biden achieve his goal of ending cancer as we know it, and we are developing promising approaches to reduce health care disparities in cancer treatment. These difficult policy challenges require investments in our human and technological cancer care infrastructure that would be virtually impossible under the current proposals.”