In its September 16, 2019 comment letter, the American College of Radiology® (ACR) urged the Centers for Medicare and Medicaid Services (CMS) to delay the start of its new Radiation Oncology (RO) Model performance period to give radiation oncologists and their practices enough time to prepare to participate in the new model.
The proposed rule (“Specialty Care Models to Improve Quality of Care and Reduce Expenditures”) was published in July 2019 with a 60-day comment period. It includes a new mandatory Medicare payment Radiation Oncology Model (RO Model) and a mandatory Medicare payment End-Stage Renal Disease Treatment Choices Model.
CMS proposed to test the RO Model for five payment years and to define the “model performance period" to mean January 1, 2020, the date the model begins, through December 31, 2024, the last date when the model must be completed.
Alternatively, CMS is considering delaying implementation until April 1, 2020, to give RO participants and CMS more time to prepare.
The ACR stressed that RO practices need at least six months to give model participants enough time to prepare for the major changes this new model will bring to their community.
Electronic health record and software developers will also be hard pressed to upgrade their products because CMS had yet to publish specific data elements as of mid-September, the ACR noted.
Hospitals typically need a year for all the necessary steps before implementing such major IT system upgrades.
In addition to its recommended delay, the ACR commented on various aspects of the RO Model, including mandatory participation, covered services, episode payment construct, site-neutral payments and its inclusion as an Advanced Alternative Payment Model.
A final rule is due to become public in mid-November. Comments and questions may be directed to Samantha Porter, ACR economics and health policy analyst.