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."

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