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ASTRO urges CMS to reconsider supervision policy and C-APC methodology in 2020 HOPPS comment letter

December 3, 2019

In the 2020 Hospital Outpatient Prospective Payment System (HOPPS) final rule, the Centers for Medicare and Medicaid Services (CMS) finalized changes to the current supervision policy for therapeutic services delivered in the hospital outpatient setting from either “direct or general” supervision to a blanket “general supervision” policy.  ASTRO issued comments in response to the final rule, urging the Agency to reconsider its position. ASTRO opposed this policy change when it was included in the proposed HOPPS rule issued in July and is disappointed that CMS is moving forward with the change despite concerns that it could potentially endanger patients’ safety. ASTRO urges radiation oncologists to work with their hospital administrators and compliance officials to adopt supervision policies specific to radiation therapy services that are in alignment with ASTRO’s APEx Accreditation StandardsSafety is No Accident and Supervision Guidance policies.

Additionally, CMS continues to expand the Comprehensive Ambulatory Payment Classification (C-APC) methodology in the 2020 HOPPS final rule. For several years, ASTRO has provided the Agency with a comprehensive analysis detailing how the methodology used to create C-APCs lacks the appropriate charge capture mechanisms and how it grossly undervalues cancer treatments, particularly brachytherapy. ASTRO is concerned that despite previous comments regarding the methodology, CMS continues to move forward with the inappropriate application of the C-APC methodology to radiation oncology services. ASTRO will continue to educate CMS on the impact that the C-APC methodology has on radiation oncology services.