The American College of Radiology® (ACR®) recently signed onto a letter with 23 other radiation oncology stakeholder organizations to President Biden urging him to prevent $300 million in Medicare payment cuts to radiation therapy resulting from implementation of the radiation oncology (RO) model in January. Under the RO Model, Medicare will pay participating providers and suppliers a prospective, modality agnostic, site-neutral, episode-based payment for specified technical and professional RT services furnished during a 90-day episode to Medicare fee-for-service beneficiaries diagnosed with 15 different cancer types. The base payment amounts for RT services included in the model will be the same for hospital outpatient departments (HOPDs) and freestanding radiation therapy centers. Cuts resulting from the RO Model would be disastrous for radiation oncology clinics across the country.
As proposed, RO Model participant-specific payment amounts are determined based on national base rates, trend factors and adjustments for each RO participant’s case-mix, historical experience and geographic location. CMS further adjusts payment amounts by applying a discount factor. The discount factor, or the set percentage by which CMS reduces an episode payment amount, reserves savings for Medicare. The discount factor for the PC is 3.5%, and the discount factor for the TC is 4.5%. The organizations ask the president to direct CMS to reduce the RO Model’s discount factor payment cuts to 3% and to hold harmless radiation oncology from cuts in the 2022 Medicare Physician Fee Schedule. Additionally, we call on President Biden to direct CMS not to proceed with discretionary policies that disproportionately harm cancer patients and direct the agency to work with Congress on other changes to ensure patients are not disproportionately affected by the policy.
Since 2019, the ACR has engaged in the CMS rulemaking process to recommend significant changes to the development of the first-ever mandatory model for our profession. Our most recent comments on the 2022 Hospital Outpatient Prospective Payment System outline specific recommendations. Significant improvements in the payment policy structure are necessary to ensure patients have access to cancer care.
For more information about the RO model, visit the CMS website.