ASTRO has sent a letter to the Center for Medicare and Medicaid Innovation (CMMI) detailing new recommendations for implementation of the RO Model that account for the impact of the COVID-19 Public health Emergency (PHE). ASTRO believes that the transition from fee-for-payment to value-based-payment through the new rule cannot be done without considering the PHE’s impact on radiation oncology practices. In the letter, ASTRO voices concerns and new recommendations focusing on mandatory participation, quality reporting, the trend factor and case mix methodology.
COVID-19 Impact and Participation:
ASTRO believes the significant impact of COVID-19 on radiation oncology practices necessitates further modifications to the RO Model before it is finalized. In particular, ASTRO is urging the Agency to reconsider requiring participation in the model. Health care and radiation oncology care has been upended by COVID-19 and this is certainly not the environment to mandate participation in a payment model that has not been tested. At minimum, ASTRO is requesting that the Agency dramatically scale back the number of required participants and allow an unlimited number of radiation oncology practices to voluntarily participate in the RO Model.
ASTRO also recommends providing a minimum of 6 months between publication of the final rule and the official RO model launch. Further, ASTRO recommends a phased in approach that would allow practices to ramp up over a period of time at their own pace while meeting predetermined benchmarks within a set amount of time.
In order to remain financially viable and capable of delivering cancer care to their communities, ASTRO believes the Agency should permanently reduce the discount factors and defer the withholds until at least year two of the model demonstration.
Further, the Agency must reverse its proposal to waive the 5% APM incentive payment to the technical component while still applying the 5% discount on the technical component as the combination has the potential to devastate freestanding practices and limit access to care.
ASTRO recommends CMS align quality reporting in the RO Model with other CMS reporting programs such as the Merit-based Incentive Payment System (MIPS) and Oncology Care Model (OCM) and minimize mandatory reporting of quality measures. Practices are facing significant clinical, operational, and financial burdens due to the PHE. Alignment with existing reporting requirements and minimizing mandatory data elements reporting will help support practices as they transition to value-based care.
ASTRO also believes that the monitoring requirements associated with the RO Model should be reconsidered. Given that CMS has had to cut back on on-site audits for OCM practices due to COVID-19 and the continued uncertainty regarding when the PHE will end, a more simplified approach should be considered. Accreditation would provide stability and predictability for practices in the RO Model.
Based on the proposed rule, 2020 utilization data will be used to inform the trend factor in 2023. Use of 2020 utilization data as part of the RO Model Trend Factor would be inappropriate given the significant declines in patient volume due to COVID-19. ASTRO urges the Agency to modify the Trend Factor methodology in 2023 to exclude 2020 data points. Instead, 2019 data should be used, as it is a more accurate representation of radiation therapy service utilization.
ASTRO urges the Agency to establish a COVID-19 case mix adjustment to account for delays in care and the resulting advance stage disease and complexity of patient cases that will present during the demonstration period. This adjustment, which should be proposed and reviewed by the radiation oncology community, should be applied to the first through third performance periods to ensure that practice payment rates adequately recognize the additional costs necessary to care for this patient population.
For more details, read the whole letter.