CMS has indefinitely delayed the start date for the alternative radiation oncology payment model.

CMS puts indefinite hold on radiation oncology model start date

April 11, 2022
by John R. Fischer, Senior Reporter
The Centers for Medicare & Medicaid Services (CMS) have indefinitely delayed the start of the new radiation oncology payment model, with no specified launch date.

The move follows legislation passed in December to delay implementing it until January 2023, according to Healthcare Innovation.

“The Protecting Medicare and American Farmers from Sequester Cuts Act (P.L. 117-71) enacted on December 10, 2021 included a provision that prohibits implementation of the Radiation Oncology Model prior to January 1, 2023. Thus, the RO Model did not begin on January 1, 2022. On April 6, 2022, CMS published a proposed rule in the Federal Register, CMS-5527-P2, which proposes to delay the current start date of the RO Model to a date to be determined through future rulemaking,” said CMS in a statement.

A replacement for the current fee-per-service payment system, the RO model is meant to improve the quality of care for radiotherapy patients by creating a simpler and more predictable payment system. It would facilitate compensation through bundled payments across a 90-day episode of care for 16 different cancers and would evaluate if these payments actually reduce Medicare expenditures while retaining or improving quality of care.

Should it go into effect, CMS expects to save $230 million over five years. Participation would be required among radiotherapy providers and suppliers that offer services in randomly selected geographic areas with approximately 30% of all eligible Medicare fee-for-service radiotherapy episodes nationwide.

The delay is meant to give participants more time to prepare for it, say CMS officials. “...multiple delays and uncertainty about the timing of the [Radiation Oncology] Model, indefinitely, will give ... participants the ability to pause their efforts to prepare for implementation of the [Radiation Oncology] model."

But they warn that the delay may create additional substantial costs for preparation of the model in 2023, including for participant onboarding, claims systems changes and updates to data used in its design and participant-specific payment amounts. Additionally, its implementation could be delayed again and more funding for it may take away resources from other payment models.

The RO model was initially supposed to take effect at the beginning of 2021 before being pushed back to July of that year. Its starting date has since been pushed back again, due to recommendations among providers and healthcare stakeholders. The model has been met with skepticism, with healthcare organizations criticizing it for staffing shortages, COVID-19-related challenges, and practice changes and investments that providers would have to make in a short period of time.

In a letter to Congress in September 2021, the American Society for Radiation Oncology wrote that the mandatory RO model would lead to cuts of $160 million over five years and prevent patients from being able to access state-of-the-art cancer treatment, along with changes suggested for the 2022 physician fee schedule. “We are asking that the RO Model's discount factors be reduced to 3 percent to safeguard access to care for patients at the 950 hospitals and community-based clinics required to participate in the model, while ensuring Medicare achieves a reasonable level of savings.”

ACR also expressed concern in October 2020 in a letter to former CMS administrator Seema Verma. “The ACR is alarmed that such a significant number of small and rural practices are included in the model, while many large metropolitan areas have been spared, and are expected to use their limited resources to adopt and implement certified EHR technology, among all of the other reporting requirements for participation,” wrote ACR chief William Thorwarth Jr.

In response to the most recent delay, ASTRO said in a statement that it supports episodic payments and hopes that CMS will implement suggested modifications. “ASTRO remains hopeful that during this process, CMS also makes the adjustments recommended by Congress and the broad coalition of stakeholders within the radiation oncology community, as we remain concerned that the model in its current form is too punitive for clinics," said ASTRO board of directors chair Dr. Laura Dawson, FASTRO. "We remain committed to value-based care in radiation oncology."