Radiation Oncology (RO) Model
The ACR conducted an initial review of provisions within the proposed rule that could introduce significant changes to the RO Model. Under the proposed rule, Medicare would pay participating providers and suppliers a site-neutral, episode-based payment for specified professional and technical radiation therapy services furnished during a 90-day episode to Medicare fee-for-service beneficiaries diagnosed with certain cancer types.
Also in the proposed rule:
- CMS will apply a 2% quality withhold from each professional episode payment after applying the trend factor, geographic adjustment, case mix and historical experience adjustments — as well as a discount factor to the national base rate. RO Model participants will have the chance to earn some or all of the withhold back based on their performance in the quality measures. CMS is proposing that RO Model participants submit quality measure data starting in the first performance year (PY1), and that starting in PY1, the 2% quality withhold for the Plan of Care will be applied.
- For PY1, participants are required to submit data for three pay-for-performance measures:
- Plan of Care for Pain.
- Screening for Depression and Follow-up Plan.
- Advance Care Plan.
- Participants would also be required to submit data for the pay-for-reporting measure: Treatment Summary Communication—Radiation Oncology.
- All quality measure data will be reported using the RO model secure data portal.
Hospital Outpatient Quality Reporting Program
The Hospital Outpatient Quality Reporting Program (HOQR) is a pay-for-quality data reporting program implemented by the CMS for outpatient hospital services. CMS is proposing to adopt a new measure for Breast Screening Recall Rates beginning in the 2022 reporting period. This new measure is an updated version of a previous Mammography Follow-up Rates measure, which did not address digital breast tomography (DBT) and was removed in 2018.
The proposed Breast Screening Recall Rates measure would calculate, by facility, the number of mammography or DBT screening Medicare fee-for-service beneficiaries who received a follow-up diagnostic mammography, DBT, ultrasound or MRI of the breast in an outpatient or office setting on the same day or within 45 days of the index image.
The goal for this measure is a recall rate of 5–12% — a higher number could signify too many false-positives, and a significantly low recall rate could lead to delayed or undetected cases of cancer. The proposed recall rate range is not based on specific clinical guidelines, but uses peer-reviewed consensus documents, including the ACR BI-RADS® Manual 2013, which support the importance of appropriate recall rates.
Clinical Data Element and Quality Measure Collection
On August 13, 2021, the ACR submitted comments to CMS on the "RO Model Quality Measure and Clinical Data Element (CDE) Collection and Submission Guide" issued for public comment as part of the 2022 Hospital Outpatient Proposed Rule.
ACR remarks addressed the CDE and quality measure data submission methods required under the RO model. The CDE Collection and Submission Guide proposes submitting this information to CMS through burdensome alternate methods, excluding the methods implemented under MIPS. The letter also emphasizes ACR concerns regarding the CMS proposal to collect duplicative and non-standardized CDEs.
ACR Summary and Comments on HOPPS Proposed Rule
Read the ACR radiology-specific summary to learn more about critical provisions in the HOPPS proposed rule that might impact radiology or radiation oncology.
The ACR submitted a comment letter about the HOPPS proposed rule to the CMS on Sept. 17, 2021.