On Jan. 29, the American College of Radiology® (ACR®) submitted a comment letter on the Radiation Oncology Model Interim Final Rule with Comment (IFC), issued as part of the Hospital Outpatient Prospective Payment System Final Rule on Dec. 2. The IFC was issued before Congress delayed the Radiation Oncology (RO) Model to Jan. 1, 2022, through the Consolidated Appropriations Act, 2021, signed into law on Dec. 27.
The ACR is in strong support of Congress’ delay of the RO Model and reiterated this appreciation in the comment letter. This delay allows more time for the ACR and other stakeholder groups to work with CMS on improving the model. Moreover, the ACR stated that they appreciate the Centers for Medicare and Medicaid Services (CMS) recognizing the challenges that the cancer care community has faced during the COVID-19 public health emergency (PHE) and for continuing to work with stakeholders.
In the comment letter, the ACR urged CMS to reduce the discount factor rates in the model to no more than 3%, as these cuts are steep for practices trying to recover from the financial impacts of the PHE. The ACR is also concerned about the inclusion of so many small and rural practices in the mandatory model. The ACR requests that the Agency use the RO Model implementation delay as an opportunity to realign the RO Model with existing reporting programs, thereby reducing burden and building upon a foundation of knowledge that many RO Model participants already have in place. RO Model participants require additional information to understand how to provide evidence of compliance with the data element and monitoring requirements.
In the correction document CMS released following the release of the RO Model final rule, CMS made significant changes to the Medicare fee-for-service impact calculations. As such, the ACR believes that CMS must conduct further rulemaking before implementation of the RO Model.
For more information on the RO Model, see CMS’ website.