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.

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