In July 2019, Centers for Medicare & Medicaid proposed the Radiation Oncology Model, an important step forward in allowing the nation’s 4500 radiation oncologists to join in the transition to value-based healthcare.
Paul Harari MD, FASTRO
In July 2019, Centers for Medicare & Medicaid (CMS) proposed the Radiation Oncology (RO) Model,1 an important step forward in allowing the nation’s 4500 radiation oncologists to join in the transition to value-based healthcare, as envisioned by the 2015 Medicare Access and CHIP Reauthorization Act (MACRA).2
The American Society for Radiation Oncology (ASTRO)—the leading medical society for members of the RO care team—submitted comments to CMS in September 2019 to express its appreciation for the agency’s decision to move forward with an alternative payment model (APM) for the specialty.3 However, ASTRO leaders have shared multiple concerns about the proposal, such as the model’s mandatory nature and its excessive payment cuts to practices. Below is a review of the strengths and shortcomings of the proposed RO Model, as well as suggested policy solutions to ensure the model can achieve its intended goals of improving patient outcomes while generating savings for Medicare.
Compared with the current fee-for-service structure that incentivizes volume over value in Medicare payment, an APM for RO could realign incentives to encourage the use of guideline-concordant and efficient patient care. A successful RO Model also could create stable and predictable payment rates that avoid jeopardizing patient access to life-saving treatments and support medical innovation while reducing administrative burden.
Our organization appreciates that CMS recognizes the effort that radiation oncologists have put into the development of an APM for their specialty, as evidenced by the fact that several elements of the proposed CMS RO Model align with the Radiation Oncology Alternative Payment Model concept paper that ASTRO submitted to CMS in April 2017.4 The positive aspects of the CMS model include the prospective payment; the episode trigger mechanism, timeline and clean period; establishment of distinct professional component and technical component payments; the inclusion of all modalities of treatment; and key quality measure elements.
We are concerned, however, that the proposed CMS RO Model falls short of meeting 3 key goals that ASTRO identified in comments submitted to CMS3 as necessary for successful, longstanding payment reform. From our perspective, an APM for RO should:
An ASTRO analysis estimates that the RO Model would cut payments to participants by approximately $320 million during the 5-year period—an excessive amount that would undermine this unique opportunity.3 Cuts of this magnitude could strain RO practices that have little choice but to take part in the model, which could put access to safe and effective radiation treatments at risk. For the RO Model to be successful, ASTRO recommends specific, significant changes that will incentivize the use of high-quality, efficient radiation therapy treatments that drive value-based reform and generate savings for Medicare. A summary of the key issues and recommended ASTRO policy solutions to address them follow:
ASTRO believes the RO Model, with significant modifications, could represent a meaningful and viable first step toward enabling the field of RO to participate in the evolving world of healthcare payment reform, as initiated by MACRA. The proposed model has serious flaws, but none of these issues are insurmountable. Radiation oncologists are committed to working with CMS to modify the model in such a way that it meets the stated goals.
This article was authored by Paul Harari, MD, FASTRO, who is professor and chairman, Department of Human Oncology, at the University of Wisconsin School of Medicine and Public Health.