Notice of Proposed Rulemaking for the Radiation Oncology (RO) Model

July 21, 2021 — On July 19, 2021, the Centers for Medicare & Medicaid Services (CMS) displayed the CY 2022 Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems (OPPS/ASC) Notice of Proposed Rulemaking (CMS-1753-P), which includes proposals related to the Radiation Oncology (RO) Model.

The RO Model tests whether prospective, site neutral, modality agnostic, episode-based payments to physician group practices (including freestanding radiation therapy centers), and hospital outpatient departments for radiotherapy (RT) episodes of care reduces Medicare expenditures while preserving or enhancing the quality of care for Medicare beneficiaries.

The RO Model has a new proposed start date of January 1, 2022, and would run for 5 performance years, ending December 31, 2026. The proposed rule also includes the following proposals:

• Adjusting the pricing methodology, including updating the baseline period to 2017-2019 and lowering the discounts to 3.5 and 4.5 percent, for the professional component and technical component, respectively.
• Removing brachytherapy from the included modalities.
• Proposing that in cases where a beneficiary switches from traditional FFS to Medicare Advantage during an episode before treatment is complete, we would consider this an incomplete episode and RT services will be paid FFS as opposed to the bundled payment.
• In light of the current PHE and several recent natural disasters, adding an extreme and uncontrollable circumstances policy. This policy would give flexibility to reduce administrative burden of Model participation, including reporting requirements, and/or adjust the payment methodology as necessary.
• Modifying the current overlap policy for the Pennsylvania Rural Health Model (PARHM) to only exclude hospitals participating in PARHM, not just PARHM-eligible hospitals, and adding an overlap policy for the Community Track of the CHART Model. The RO Model would follow the same policy for overlap between the RO Model and the Medicare Shared Savings Program ACOs for the CHART ACO Transformation Track.

In addition to these proposals, CMS is removing liver cancer from the RO Model. CMS also includes clarifications in the NPRM to help address questions from stakeholders and future RO participants related to the interaction between the RO Model and the Quality Payment Program. 

CMS is seeking comment on these proposals.

For more information, reference the RO Model: https://innovation.cms.gov/innovation-models/radiation-oncology-model

For questions on the RO Model or for RO participants seeking to attain their RO Model ID: RadiationTherapy@cms.hhs.gov

Related RO Model content:

ASTRO Responds to Troubling Medicare Cuts, Radiation Oncology Model Update