Though the radiation oncology model proposed by the CMS has some positive elements, it fails to meet three major goals set forth by ASTRO, said Dr. Paul Harari, chair of the ASTRO Board of Directors in a statement. These goals include rewarding radiation oncologists for participating in initiatives to improve patient care, ensuring fair and predictable payment for radiation oncologists, and incentivizing the appropriate use of cancer treatments.
Furthermore, the CMS proposed model would reduce payments in radiation oncology by an estimated $320 million throughout the course of its designated five-year use period, Harari noted. In its response to the CMS, ASTRO recommended several specific changes to the proposal:
- Voluntary participation: Participation in the yet untested proposed payment model should be voluntary at first and only become mandatory on a limited basis.
- Costs: CMS should incorporate some physician fee schedule costs into the payment model, with proper attribution for palliative care cases and adequate payment for patients undergoing standard-of-care multimodality treatments.
- Adjustments for efficiency: CMS could avoid unnecessarily penalizing efficient practices by adjusting the efficiency factor and easing up on the discount factors.
- No incentive payment waiver: There should be no selective waiver for the 5% alternative payment model incentive payment on freestanding center technical payments.
- Payment for innovation: Participants should be reimbursed for the use of new technology through fee-for-service rates.
- Reduce administrative burden: Many of the requirements imposed on radiation oncology practices should be delayed until they can be adapted based on recommendations from the radiation oncology community.
"We are committed to working with the [CMS] to modify the model in such a way that it meets the stated goals," Harari wrote.
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