On Dec. 2, the Centers for Medicare and Medicaid Services (CMS) released the Calendar Year (CY) 2021 Hospital Outpatient Prospective Payment System (HOPPS) final rule. Within the HOPPS final rule, CMS formally delayed the Radiation Oncology (RO) Model and made other provisions that accompany this delay through an interim final rule with comment period.
On Sept. 29, CMS released the RO Model final rule. On Oct. 21, the agency announced that they intended to delay the start date of the model from Jan. 1, 2021 to July 1, 2021, as encouraged by advocacy efforts of the American College of Radiology® (ACR®), and would do so through future rulemaking. The interim final rule with comment period pertaining to the RO Model included in the CY2021 HOPPS final rule outlines the delay and its implications on the model. For example, as a result of the delay, the model will not qualify as an advanced alternative payment model (APM) or MIPS APM for Performance Year (PY) 1 of the model. Other provisions for the model include:
- Collection of quality measures and clinical data elements will not be required until PY2.
- There will not be a quality withhold for PY1.
- The aggregate quality score will be applied beginning in PY2.
- The RO Model performance period will now be 4.5 years, from July 1, 2021 to Dec. 31, 2025.
- The Certified Electronic Health Record Technology requirement will start in PY2.
- The individual practitioner list will still be required in PY1, but will only be used to assign an automatic 50% score for the Improvement Activity performance category in MIPS for participants.
- A CMS contractor will distribute the CAHPS survey starting in October 2021.
- Both episodes and RO episodes from 2021 will determine eligibility for the low-volume opt-out for PY3.
There is a 60-day public comment period following the release of this interim final rule, and the ACR plans to provide comments to CMS.