CMS Delays Radiation Oncology Model With No New Start Date

The Radiation Oncology Model has been delayed indefinitely under a final rule released by CMS on Thursday.

The alternative payment and care delivery model for cancer care aims to improve quality of care for patients who receive radiotherapy and establish a predictive, simple payment system for providers who deliver those services. The model would do that through site-neutral bundled payments for a 90-day episode of radiotherapy and related services. Providers in randomly selected areas would be required to participate, according to program rules.

However, cancer care providers have questioned the model’s methodology—particularly its mandatory nature—since CMS announced it in 2019.

Criticism from industry stakeholders prompted CMS to push back the original launch date of the Radiation Oncology Model. The model was slated to start on January 1, 2021, and CMS pushed that date to July 1, 2021.

However, the Radiation Oncology Model never made its debut in the summer of 2021. Instead, Congress has delayed the state of the model over concerns about the COVID-19 pandemic and its impact on healthcare providers. Most recently, lawmakers delayed the model again through the Protecting Medicare and American Farmers from Sequester Cuts Act, which prohibited CMS from implementing the model prior to January 1, 2023.

CMS said in the final rule that it continues to believe that the Radiation Oncology Model “would address long-standing concerns related to RT delivery and payment, including the lack of site neutrality for payments, incentives that encourage volume of services over the value of services, and coding and payment challenges.”

However, CMS decided to postpone the launch date given the legislative delays and persistent criticisms from industry stakeholders who have called for change. The agency also announced in the final rule that it would redefine the performance periods.

Moving forward, CMS plans to propose a new start date “no less than 6 months prior to that proposed start date.”

The American Society for Radiation Oncology (ASTRO) said in a comment given by Board of Directors Chair Laura A. Dawson, MD, FASTRO, that this indefinite delay of the Radiation Oncology Model “provides an opportunity for CMS to  work with stakeholders on a new value-based reimbursement structure for radiation therapy.”

ASTRO is one of the industry groups that submitted concerns about the model, arguing that the model emphasized cost savings over quality of care. The group has also expressed concerns that the model, which CMS estimated would reduce payments to radiation oncologists by $15 million, would add to the financial problems these providers are already facing because of Medicare reimbursement cuts.

Other groups, including the Community Oncology Alliance (COA) and the American Hospital Association (AHA), have also called for changes to the Radiation Oncology Model. Critics have said making the model mandatory for providers in certain areas could disrupt needed care for vulnerable patients, while others have critiqued the discount factors CMS plans to use—the steepest in any alternative payment model at 3.5 percent for the professional component and 4.5 percent for the technical component.

Despite their criticism of the Radiation Oncology Model, ASTRO believes that episodic or bundled payments such as those proposed under the Radiation Oncology Model could improve access and quality, as well as reduce costs and advance health equity.

“Fair and stable Medicare payments are essential to support modern cancer care, especially as clinics face rising inflation costs. We are optimistic that CMS will work more closely with the radiation oncology community on a reformed push for episodic payments,” Dawson stated.