AHA Recommends Changes to Radiation Oncology Model Following Delay

The American Hospital Association (AHA) has recommended changes to the CMS Radiation Oncology (RO) Model following the agency’s decision to delay the model’s start date.

In a letter to CMS Administrator Chiquita Brooks-LaSure, AHA expressed support for the original goals of the RO model to ensure fair and predictable payments for radiation oncologists. But the organization noted that payment cuts and accompanying administrative burden have warped the model’s intentions.

In April 2022, CMS proposed an implementation delay until a start date determined by future rulemaking. AHA supported this decision and offered a series of modifications that CMS should consider before moving forward with the RO model.

The hospital organization voiced concerns about the discount factors under the RO model. The model included a discount factor of 3.5 percent for the professional component (PC) and 4.5 percent for the technical component (TC).

“The amount and application of these discount amounts, and the uneven playing field they created both within the model and between participants and those excluded from the model, was extremely concerning to us — as well as others,” AHA wrote.

The discount sizes are the largest that CMS has ever proposed for a bundled payment model, the letter noted.

In addition, AHA said it was confused as to why the TC discount factor was higher than the PC discount factor. Hospital TC providers cannot impact the treatment plan or episode cost but make all the capital investments for radiation therapy, the letter stated.

However, hospital TC providers cannot earn a 5 percent advanced APM bonus under the Quality Payment Program for participating in the model like PC providers can.

AHA urged CMS to lower the TC and PC discounts to 3 percent or less to ensure patients maintain access to radiation therapy services.

The organization also asked CMS to apply future stop-loss policies to all participants instead of only participants with 60 or fewer episodes during the baseline period.

“We do not understand this limitation — the number of episodes a participant performs is unrelated to case complexity, for which stop-loss policies are designed to account,” the letter read. “We are worried that under this policy, outlier patients could have lost access to services either at their home facility or at highly specialized locations to which they travel for care.”

The RO model includes 15 cancer types, which AHA said makes it too broad to be a mandatory program. After reimbursement cuts due to the discount factors, some hospitals and health systems may not have the finances to invest in the design elements of the model. Therefore, AHA requested that CMS include only cancers for which there is strong clinical evidence for various treatments, such as prostate, breast, and lung cancers.

Finally, AHA mentioned concerns about the RO model’s quality measures, encouraging CMS to only use measures endorsed by the National Quality Forum (NQF). In addition, AHA urged the agency to consider using a pay-for-reporting approach during the model’s first year before transitioning to a performance-based calculation.

The letter also noted that the model’s requirement to report basic clinical information that is not available in claims or captured in the quality measures would create a significant burden for hospitals and would not benefit patients or CMS.

The RO model has received pushback from healthcare stakeholders since CMS proposed the model in 2019.

For example, the Community Oncology Alliance (COA) stated that a mandatory bundled payment model for radiation oncology could detract from quality patient care and interfere with established cancer care models.

In response to negative feedback, CMS delayed the model’s start date for the first time in October 2020. The model was initially slated to begin on January 1, 2021, but the agency delayed it to July 1, 2021. Since then, the start date has been continuously delayed, mainly due to federal legislation.