Stephanie Kriston

Challenges and opportunities in implementing the Radiation Oncology Alternative Payment Model (RO-APM)

August 15, 2022
By Stephanie Kriston

Beginning as early as April 2023, many providers of radiation oncology (RO) services may face new requirements for collecting and reporting clinical quality measures (CQM) data and clinical data elements (CDE) to qualify for maximum Centers for Medicare and Medicaid Services (CMS) reimbursement for covered services provided to Medicare beneficiaries. These new requirements are being implemented under the Radiation Oncology Alternative Payment Model (RO Model), an advanced alternative payment model intended to incentivize RO providers to deliver services more efficiently while maintaining or improving the quality of care delivered.

Developed by CMS in conjunction with the Center for Medicare and Medicaid Innovation, the RO Model pays providers a predetermined, site-neutral, bundled rate for most radiation therapy services provided within a 90-day episode of care, rather than paying for each service individually.

Care sites that CMS selects for participation in the initial RO Model pilot program will collect CDEs for prostate, breast and lung cancers, in addition to bone and brain metastases. These data collection requirements are just one aspect of the changes to which radiation oncology providers and practices will need to adapt in order to comply with and receive maximum reimbursement under the RO Model.

Complying with the RO Model presents radiation oncology centers with a variety of challenges
In many situations change does not come easily, and the healthcare landscape is no exception. A key challenge to complying with the new RO Model requirements is the need to collect and analyze additional data that may not be part of a care center’s routine processes. Another challenge is that, at least initially, RO Model analyses and reporting will only be required for a defined subsets of patients with specific cancer diagnoses, i.e. Medicare beneficiaries with prostate, breast or lung cancers, or bone and brain metastases. This specification requires separate tracking of these patients within a care center’s overall patient population. Finally, data reported under the RO Model must conform to specific formatting requirements that may not be consistent with a care center’s current practices and may not be readily implemented using existing data collection, analysis and reporting systems and infrastructure.

Minimizing the burden that RO Model compliance places on care providers and administrators will take careful and proactive planning to identify and address processes and personnel impacted by the new requirements. At a minimum, care centers participating in the test program will need to update their billing systems to accommodate RO Model payment structures and reimbursement. It is also likely that multi-site care centers will also need to identify solutions that address the increased complexity of tracking patients and payments if they may have one or more sites assigned to the pilot program as well as sites that are not subject to the reporting requirements.

Leveraging technology to address the challenges of RO Model implementation
While the RO Model creates new challenges for RO care centers, technology can be used to facilitate streamlined and accurate RO Model reporting and provide actionable data that RO centers can use to improve the quality and efficiency of the care they provide. Software solutions that include modules and reporting features specifically designed to fulfill RO- Model requirements and minimize data entry errors by pulling information directly from a care center’s electronic health records system can help transform the challenges of RO-Model reporting into opportunities to gain greater insight into critical aspects of care delivery, efficiency, and quality – better enabling them to achieve their value-based care objectives. A technology solution that provides premade reporting templates and customizable features can help care centers meet RO Model-specific and site-specific needs. I was part of a collaborative effort between Elekta and RO care providers to develop MOSAIQ Oncology Analytics (MOA), a software solution intentionally designed to meet these real-world needs.

Transforming challenges into opportunities
While care centers specified as RO Model sites must comply with the new data collection and analysis requirements, the outputs of these analyses can be highly beneficial to all RO providers. Gaining more granular insight into care delivery processes, outputs, and costs is essential for refining and optimizing clinical workflows, staffing, and investment in equipment and other resources. Although the RO Model initially is being deployed as a pilot program, it will likely be broadly implemented if it is shown to improve the efficiency and/or quality of RO care delivery. Consequently, investing in RO Model solutions today will make it easier to adapt to the continued evolution of the RO payment and reimbursement landscape.

Importantly, implementation of the RO Model, even at just the pilot level, will have broad effects on the economics of providing RO services. Understanding the impact of these effects is critical for developing robust and accurate financial models that support effective financial decision-making and allow RI centers to grow, thrive, and provide high-quality care in a dynamic reimbursement environment. The RO Model is a harbinger of the evolving economics of radiation oncology and also exemplifies the ongoing push toward value-based payment models. Implementing software solutions that support the delivery of highest-quality care as efficiently and as cost-effectively as possible will benefit patients and providers, whether it’s required or not.

About the author: Stephanie Kriston is the senior director of health policy, market access and reimbursement at Elekta.