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Top Line: Feel something tingly on the back of your neck?
The Proposed Rule: It’s here—the radiation oncology alternative payment model (APM). Yesterday, the Centers for Medicare & Medicaid Services (CMS) released the RO Model proposal, and it even comes with its own website. The proposal is huge, and we read through a lot of it, but TBH we got tired at “Pricing Methodology.” The prologue provides an interesting backstory of what likely prompted CMS to go this route, where they specifically point out discrepancies in payments to free-standing versus hospital-outpatient centers. Free-standing centers, for various reasons, received 11% more per episode of care despite lower payments per unit of service. So the heart of the proposal is a site-neutral, and modality neutral, payment system. First, what is it? The RO Model will bundle payments for all radiation services over a 90-day treatment period triggered by initial treatment planning. The payments are still split between professional and technical services and are incentivized for quality, patient experience, and data reporting. Second, who does it affect? Zip codes that fall within randomly selected core-based statistical areas, where they plan a mandatory inclusion of 40% of all episodes of care in the initial run. Importantly, though, it affects only beneficiaries with traditional CMS (not managed care or advantage) plans. Oh yeah, and proton therapy is included in the standard bundles. Ouch. Finally, when would it start? CMS wants to start on 1/1/2020, but “would consider" delaying until 4/1/2020, with a plan to last 5 years through 2024.
TBL: CMS is now accepting comments on the proposed RO Model (Proposed Rule CMS-5527-P). | CMS 2019
The Proposed Rule: It’s here—the radiation oncology alternative payment model (APM). Yesterday, the Centers for Medicare & Medicaid Services (CMS) released the RO Model proposal, and it even comes with its own website. The proposal is huge, and we read through a lot of it, but TBH we got tired at “Pricing Methodology.” The prologue provides an interesting backstory of what likely prompted CMS to go this route, where they specifically point out discrepancies in payments to free-standing versus hospital-outpatient centers. Free-standing centers, for various reasons, received 11% more per episode of care despite lower payments per unit of service. So the heart of the proposal is a site-neutral, and modality neutral, payment system. First, what is it? The RO Model will bundle payments for all radiation services over a 90-day treatment period triggered by initial treatment planning. The payments are still split between professional and technical services and are incentivized for quality, patient experience, and data reporting. Second, who does it affect? Zip codes that fall within randomly selected core-based statistical areas, where they plan a mandatory inclusion of 40% of all episodes of care in the initial run. Importantly, though, it affects only beneficiaries with traditional CMS (not managed care or advantage) plans. Oh yeah, and proton therapy is included in the standard bundles. Ouch. Finally, when would it start? CMS wants to start on 1/1/2020, but “would consider" delaying until 4/1/2020, with a plan to last 5 years through 2024.
TBL: CMS is now accepting comments on the proposed RO Model (Proposed Rule CMS-5527-P). | CMS 2019
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