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• National Case Rates: The calculations for the national case rates would result in a significant and unfair payment penalty for participants, according to ASTRO. It says that the methodology does not appropriately account for a range of complex clinical scenarios and average treatment costs faced by many clinics. It asserts that CMS must include some physician fee schedule costs, properly attribute palliative care cases, and ensure adequate payments for patients receiving standard-of-care multi-modality treatments, such as combination therapy for gynecological cancer.
• Discount Factor and Efficiency Adjustment: The RO model’s proposed payment adjustments may lead to significant cuts to all participants and unfairly disadvantage "efficient" practices. CMS should adjust the efficiency factor to avoid penalizing these practices, and scale back the discount factors, which put access to care for patients at risk by creating financial issues for such a capital expenditure-intensive specialty.
• APM Incentive Payment: CMS should remove its selective waiver of the five percent APM incentive payment on freestanding center technical payments, because it undercuts MACRA’s encouragement of providers to assume risk and participate in APMs.
• Innovation: The RO Model does not adequately consider future advances in the delivery of radiation oncology. Practices should continue investing in innovations that provide clinical benefit for patients, and CMS should pay for new technology at fee-for-service rates, and adopt a rate review mechanism for new service lines and upgrades.
• Burden: The RO model would add more administrative tasks and costly requirements on already burdened radiation oncology practices that are required to participate in it. CMS should delay many of these requirements and instead go by recommendations from the radiation oncology community to ensure that the most meaningful and least burdensome information is collected.
Despite these critiques, ASTRO applauded CMS’ efforts to create a more efficient model, some of which, it admits, conforms with the recommendations of the Radiation Oncology Alternative Payment model concept paper submitted by ASTRO in April 2017. These include its views on prospective payment; the episode trigger mechanism, timeline and clean period; the establishment of distinct professional component and technical component payments; the inclusion of all modalities of treatment; and key quality measure elements.
