On Oct 1, the American College of Radiology® (ACR®) sent a letter to the Centers for Medicare and Medicaid Services (CMS) urging the agency to delay the implementation date of the Radiation Oncology (RO) Model and to reduce the excessive payment cuts to mandatory participants. The RO Model final rule, released Sept. 18, determined that the model will begin on Jan. 1, 2021. The ACR has asked CMS to delay the start date until at least July 1, 2021, due to the ongoing impacts of the COVID-19 pandemic. In July 2020, the ACR sent a letter to CMS recommending that the agency allow providers at least six months between publication of the final rule and its implementation date. The ACR is concerned that CMS has given mandatory participants three and a half months to prepare in the midst of a public health emergency (PHE).
The ACR is disappointed that the agency did not consider any of the other recommendations made in the July 2020 letter to CMS in response to the PHE. Mandatory participation representing 30% of eligible episodes, although an improvement from the proposed 40%, goes too far for an untested model. The ACR is alarmed that such a significant number of small and rural practices are included in the model, while many large metropolitan areas have been spared, and are expected to use their limited resources to adopt and implement certified EHR technology, among all of the other reporting requirements for participation.
The ACR also signed on to a stakeholder letter led by the American Society for Radiation Oncology (ASTRO) that was sent to CMS on Oct. 2. In the letter, the ACR, ASTRO, the American Medical Association and other stakeholders urge CMS to reverse course and delay implementation of the model to Jan.1, 2022, or — at the earliest — July 1, 2021, and to reduce the discount factors to 3%. The letter emphasizes to CMS that radiation oncology group practices and hospital outpatient departments have faced severe challenges due to the COVID-19 pandemic, including reduced patient volumes and increased supply costs. Therefore, a mandated model that distracts from patient care and increases worries of financial strain with the payment cuts is impractical, especially now.