Radiation oncologists are applauding the Centers for Medicare & Medicaid Services’ introduction of a test radiation oncology alternative payment model (APM) to help encourage the move to value-based care, but concerns, particularly about its mandatory participation, have been raised.
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The proposed radiation oncology APM, posted online as part of a larger notice of proposed rulemaking on July 10 and scheduled for publication in the Federal Register on July 18, will be tested over a 5-year period to determine if a prospective, site-neutral, episode-based payment for radiation therapy will improve the quality of care and lower costs for Medicare. Comments on the proposal are due 60 days from Federal Register publication.
According to the CMS website, the agency would make “prospective, episode-based (i.e. bundled) payments, based on a patient’s cancer diagnosis, that would cover radiotherapy services furnished in a 90-day episode for the 17 cancer types meeting the included cancer type criteria.”
The site-neutral payments would be based on a “common, adjusted national base payment amount” and would contain two components (professional and technical) “to allow for use of current claims systems for PFS [physician fee schedule] and OPPS [outpatient prospective payment system] to be used to adjudicate RO (radiation oncology) Model claims and be consistent with existing business relationships.”
Payments would be linked to quality “using reporting and performance on quality measures, clinical data reporting, and patient experience as factors when determining payment to participants.” The radiation oncology model qualifies as an advanced alternative payment model under the Quality Payment Program.
In addition to measuring whether the model improves quality and lowers costs, CMS will be studying whether it results in shorter courses of radiation therapy, more efficient care delivery, and higher-value care for Medicare beneficiaries.
The biggest detail about this proposed alternative payment model that is raising some red flags within the community is that it has a mandatory participation requirement, with participation determined by a random selection of providers in selected geographic areas.
The Community Oncology Alliance said in a statement that it has “deep reservations and fundamental opposition to a proposed mandatory or ‘required’ Center for Medicare & Medicaid Innovation model. Radiation therapy is a powerful, complex part of cancer care for patients. While the proposed CMMI model does include a much-needed policy proposal to implement site-neutral payments, COA absolutely does not support mandatory CMMI models,” adding that if models are “reasonable and would advance value-based care, then voluntary provider participation would be robust.”
Dave Adler, vice president of advocacy at the American Society for Radiation Oncology, also expressed concern regarding the requirement for participation.
“At least at the outset, having a voluntary model is the right way to start,” he said in an interview. “This is something that has not been tested before. I think it’s really important to its long-term success that we understand its impact on providers and patients before it’s required for anybody.”
He offered a little flexibility on that stance, noting that if CMS would not budge on the mandatory aspect, he suggested that it lower the amount of participation that will be required from the proposed 40% of radiation oncologists to something smaller, coupled with a mechanism for voluntary participation, which does not exist in the current proposal.
Outside of that immediate concern, Mr. Adler said it was really too early to tell whether the proposal is in fact adequate to meet the needs of practicing radiation oncologists, including the payment rates, and the patients they treat. He said ASTRO will be doing a deeper analysis in the coming weeks and will provide the necessary feedback to CMS on the proposal.