ACCC Comments to CMS on Proposed RO Model

On September 16, the Association of Cancer Care Centers (ACCC) submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the agency's proposed Radiation Oncology (RO) Model rule.

In its comment letter, ACCC expresses committed support for the movement toward value-based care, noting that ACCC members have long been leaders in developing and participating in value-based payment systems.

As CMS looks to finalize a model for radiation oncology, ACCC urges the agency to:

• Make significant changes to the proposed episode payment methodology to ensure that the RO Model incentivizes innovation and cost-efficient care while allowing for equitable treatment of model participants.
• Phase in mandatory participation in the RO Model to ensure equitable opportunity for success and ensure accurate and useful results from the model.
• Delay the start of the RO Model until July 1, 2020 at a minimum.
• Finalize the proposed exclusion of radiopharmaceuticals and certain brachytherapy surgical procedures from services covered by bundled payment.
• Begin a new RT episode when a new course of treatment begins before a pending 90-day RT episode is complete.
• Clarify certain aspects of the proposed quality reporting requirements.
• Reconsider the uncompensated burden that would be required to comply with proposed monitoring and peer review requirements, which are not tied to pay for reporting.
• Apply the 5 percent Advanced Alternative Payment Model (APM) incentive payment to the technical component of the RO Model payments as well as the professional component.
• Structure the final RO Model so that all participants will be qualifying participants in an Advanced APM for purposes of the QPP, assuming minimum participation requirements are met.
• Open the RO Model to voluntary participation by the Medicare Advantage plans and other payers.
• Clarify how the RO Model will overlap with the Oncology Care Model (OCM) in a manner that allows for full and fair participation in both models.

Read ACCC's comment letter.

Posted 9/23/2019