By Michael Kuettel, MD, PhD, MBA, FASTRO, ASTRO’s Health Policy Council Chair
ASTRO has pushed back on recent major Medicare proposals that would cut payments for radiation oncology services.
The Centers for Medicare and Medicaid Services (CMS) issued its proposed 2019 Medicare Physician Fee Schedule (MPFS
) in July, with a troubling 2 percent cut to radiation oncology reimbursement. All radiation oncologists, regardless of whether they practice in a hospital or freestanding setting, receive payments under the physician fee schedule, which is why ASTRO devotes extensive resources to analyzing and advocating on these policies.
The proposed cuts for next year stem from two policy changes. First, reductions in prices for key radiation therapy supplies and equipment, including some big cuts for stereotactic radiosurgery systems and brachytherapy equipment. Second, a huge shift in CMS’s approach to evaluation and management (E&M) codes, resulting in a single rate for certain new and ongoing visits paired with reduced documentation requirements.
ASTRO asked CMS in comments
to reconsider several equipment price changes after reviewing invoices showing higher prices for that equipment. On the E&M revision, ASTRO suggested modifications that would ensure radiation oncology could bill a proposed new code for complex visits and an increase in the total value of these codes so radiation oncologists would not suffer payment cuts for these critical services. If CMS adopts ASTRO’s recommendations, radiation oncology would likely receive stable payments for 2019, as the specialty moves toward adoption of a Radiation Oncology Alternative Payment Model (RO-APM).
The proposed MPFS also includes modifications to the 2019 Quality Payment Program (QPP). ASTRO is concerned that practices participating in the QPP’s Merit-based Incentive Payment System (MIPS) are not realizing sufficient incentive payments to offset the costs of compliance. ASTRO continues urging CMS to make MIPS changes to ease participation for radiation oncologists while moving forward with a RO-APM.
CMS has also issued the 2019 Hospital Outpatient Prospective Payment System (HOPPS
) proposed rule. HOPPS is important to ASTRO because payments go to hospitals to reimburse the technical component of radiation oncology services. The HOPPS rule continues an expansion of the Comprehensive-Ambulatory Payment Classification (C-APC) methodology and includes modest changes to the proposed rates for radiation oncology services for 2019. CMS proposes a new device pass-through payment for the hydrogel spacer.
ASTRO submitted HOPPS comments
, expressing ongoing concern that the C-APC methodology fails to adequately account for radiation oncology services. ASTRO also supported the hydrogel spacer pass-through payment based on evidence showing the material reduces toxicity for patients treated with radiation therapy for prostate cancer.
To learn more about the proposed rules at the ASTRO Annual Meeting, attend the 2019 Coding and Reimbursement Update
on Monday, October 22, from 7:45 a.m. – 9:00 a.m. in Room 206. Also, keep an eye out for the final payment rules, which will will be released in November and will be effective January 1, 2019. ASTRO will host a 2019 Final Rules webinar to summarize the key issues impacting radiation oncology in both the MPFS and HOPPS on December 5, at 1:00 p.m. Eastern time.
In addition, for the latest in-depth information on health policy issues facing radiation oncology, attend the ASTRO’s 2018 Winter Coding and Coverage Seminar
at its headquarters in Arlington, Virginia, December 7–8. This in-person workshop allows participants to hear from experts on top coding and coverage issues, including how these rules will impact their practice. ASTRO's Clinical Affairs department will be hosting MIPS office hours on-site where you can ask questions specific to your practice on the changes to the QPP.
See ASTRO’s or more details on radiation oncology payment, go to www.astro.org/Daily-Practice