Proposed rule updates for the Radiation Oncology Model

The new Radiation Oncology alternative payment model will start Jan. 1, 2022, after the proposal is finalized in the calendar year 2022 Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System final rule, scheduled for early November. This rule will require prospective hospital outpatient departments, physician practices and freestanding clinics providing radiation therapy services to adopt a prospective bundled payment model with new clinical and quality measure reporting requirements.

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 update

The 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 update

Most 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 update

CMS 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.

Exclusion criteria update

An extreme and uncontrollable circumstances policy is proposed for the RO Model, allowing flexibilities to reduce administrative burdens associated with participating in the model when there is an extreme or uncontrollable circumstance affecting an entire region or locale. This allows CMS to amend the model performance period, eliminate or delay reporting requirements or amend the pricing methodology under the RO Model when there is an extreme or uncontrollable circumstance declared impacting a provider’s ability to deliver care according to the model requirements.

How to prepare

To ensure successful participation, healthcare providers must begin planning now for these proposed rule updates, new quality measures and reporting requirements. Learn how DataGen can help your practice prepare for this new alternative payment model through Performance Period Monitoring for Alternative Payment Models.