The RO Model aims to test whether prospective, site neutral, episode-based payments to physician group practices and hospital outpatient departments for radiotherapy episodes of care would reduce Medicare expenditures while preserving or enhancing the quality of care for Medicare beneficiaries. The Model’s episode payment is designed “to give radiotherapy providers and suppliers greater predictability in payment and greater opportunity to clinically manage the episode, rather than being driven by fee-for-service (FFS) payment incentives.” Radiation therapy providers and suppliers have been randomly selected for participation based on Core-Based Statistical Areas (CBSAs), and 33 sites from 14 practices in The Network are included in the zip codes selected for participation.
In November 2021, the Centers for Medicare & Medicaid Services (CMS) and the Center for Medicare and Medicaid Innovation (CMMI) issued a final rule making slight revisions to the Radiation Oncology (RO) Model, including updating the model’s base rates, removing liver cancer and brachytherapy, and lowering the discounts from 3.75% to 3.5% for the professional component and 4.75% to 4.5% for the technical component, and adopting an extreme and uncontrollable circumstances policy. The RO Model was set to begin on January 1, 2022.
At the same time, radiation oncology was looking at a waterfall of Medicare payment cuts set to take effect on January 1, 2022, including the expiration of the temporary 3.75% payment bump and the 2% sequester moratorium, as well as cuts related to policy changes in the CY 2022 Medicare Physician Fee Schedule. The Network urged CMS to “consider the holistic impact of cuts stemming from the RO Model, the PFS, and the COVID-19 pandemic to freestanding oncology practices to ensure the Model doesn’t lead to further consolidation.” The Network also joined industry stakeholders in calling on Congress to address these cuts before the end of the year. On December 9, 2021, Congress passed a special Medicare package mitigating many of these payments cuts and delaying the RO Model until January 1, 2023.
On April 6, 2022, CMS issued a proposed rule that would indefinitely delay the Radiation Oncology Model. In the rule, CMS cited the two legislative delays, stakeholder comments indicating they would not support the RO Model unless specific changes were made, and the cost of continuing to fund preparation for implementation of the RO Model that is taking resources away from the development of other alternative payment models. Read more about The US Oncology Network’s response to this proposal here.
The Network will continue working with CMS and Congress to advance more meaningful practice transformation and maintain the viability of community cancer practices.
To learn more about The Network’s advocacy on the RO Model: