The model is mandatory for participants selected by CMS.
The new RO model includes several notable changes that must be addressed for successful participation:
Disease sites updateThe criteria for cancer types have been clarified. Cancer types must be:
- commonly treated with radiation therapy according to nationally recognized evidence-based guidelines;
- associated with ICD-10 codes that demonstrate pricing stability; and
- not determined to be unsuitable for inclusion by the HHS Secretary.
As a result of the updated criteria, liver cancer was removed since there is limited guidance for first line use of radiotherapy for treatment. Sixteen cancer types remain included under the proposed RO Model.
Modalities of treatment updateMost radiation therapy services will be covered, including treatment planning, dose planning, radiation physicians and dosimetry, treatment devices, image guidance, special services, treatment delivery and treatment management.
Brachytherapy was removed from the list of included radiation therapy treatment modalities. The removal of this modality came out of concern for how episodes using two or more types of radiation therapy treatment would be handled and the potential disincentive its inclusion in the RO Model could create for cases where it is clinically indicated.
Performance period update:The baseline period was updated to the CY 2017-2019 period if the model begins in 2022. This performance period impacts the calculation of national base rates and participant-specific adjustment factors that determine the professional component and technical component episode payment amounts for participants.
In addition, the discount factors were proposed to be lowered by 0.25% for each component of the model.
RO Model participant updateCMS issued a ZIP code list detailing the locations of prospective participants. These include physician group practices, freestanding centers and hospital-based outpatient departments providing radiation therapy specific episodes of care.
Several RO participant exclusions were modified:
- Hospital outpatient departments participating in the Pennsylvania Rural Health Model will not be eligible to participate.
- HOPDs in the Community Transformation track of the CHART Model will not be eligible to participate.
- HOPDs in the ACO Transformation track of the CHART Model will be eligible to participate in the RO Model and CMS will apply the same overlap policy that has been proposed for MSSP ACOs.