By Constantine Mantz, MD, ASTRO Health Policy Council Vice-chair
In the last two weeks, I’ve joined fellow ASTRO advocacy leaders in critical meetings with senior officials at the Centers for Medicare and Medicaid Services (CMS) on a variety of pressing payment issues facing the specialty.
The Radiation Oncology Model (RO Model), of course, continues to be the focus of ASTRO’s attention, as we continue pressing the Trump administration on necessary reforms. However, with the RO Model final rule going through the last stages of administration clearance, federal rules restrict agency staff from discussing the model. ASTRO continues to expect the model to be released in 2020. Contrary to rumors, there is no delay and practices should be preparing.
The key issues on our agenda for these meetings were those keeping me, ASTRO leaders and the membership up at night: How can recent payment stability be maintained? How can new medical oncology-focused payment models ensure appropriate radiation therapy utilization?
Given that the Agency is pursuing formal rulemaking on all of these issues, the ASTRO team did not expect to hear any final answers to these key questions from the high-level staff at the CMS’ Hospital and Ambulatory Payment Group (HAPG), which oversees physician fee schedule and hospital outpatient payments, nor the senior team at the Center for Medicare and Medicaid Innovation (CMMI), which is responsible for oncology alternative payment models, including the RO Model and the next iteration of the Oncology Care Model (OCM), known as Oncology Care First. Instead, these meetings provided an opportunity for ASTRO to press our case face-to-face with decision makers, enhancing our numerous letters with real-world illustrations of how Medicare payment policy impacts clinical and business decisions on the ground in radiation oncology.
On February 4, the ASTRO team met in Baltimore with CMS HAPG senior staff to urge the agency to again extend the G codes and payment rates for treatment delivery, IMRT and image guidance delivered in freestanding centers under the physician fee schedule until the end of 2021. ASTRO initiated and extended this payment freeze through legislation, and successfully advocated for CMS to continue the freeze through its regulatory authority in 2020. As the radiation oncology community transitions to the RO Model, which has numerous components that are linked with the physician fee schedule, we argued that continued payment stability in the fee schedule is essential to ensure successful adoption of value-based radiation oncology payments.
In addition, ASTRO again discussed the need for the agency to increase reimbursement for hospital-based brachytherapy payments, most notably for cervical cancer, where there is a gap in covering the costs of the standard of care due to CMS’ approach to packaging payments. ASTRO appreciated the HAPG attention to our issues, and we look forward to seeing the direction CMS takes when the Agency releases proposed payment rules for hospitals and freestanding centers this summer.
On February 18, our team returned to Baltimore to meet with CMMI to discuss concerns that radiation therapy utilization may be shrinking inappropriately under the OCM. We focused on ASTRO’s longstanding concerns about the perverse incentives to reduce radiation therapy utilization under the OCM. Our goal was to convince CMMI to avoid replicating the problem in the next iteration of the model, and we left with a better understanding of the Agency’s goals and agreement to explore some potential fixes that ensure radiation oncologists are better positioned under the model to be equal partners in multidisciplinary cancer care with other cancer specialists.
Each time I travel to CMS offices, I’m struck by the candid and constructive discussions we have with policymakers as we work to solve the complex radiation oncology health policy problems to the benefit of our patients. While we may not always agree with the Agency, ASTRO has established itself as a credible voice with key officials, and the data and ideas we provide are treated with respect.
When the RO Model final rule and other Medicare payment rules are released in coming months, ASTRO will be ready with a strong response that protects cancer patients’ access to radiation therapy.