Blog Post

Mandatory CMS Radiation Oncology Model Delayed Again

Mandatory Cms Radiation Oncology Model Delayed Again Web

Last week, via the stimulus bill (Consolidated Appropriations Act, 2021 [H.R. 133]), Congress further delayed the Radiation Oncology (RO) Model, which is now expected to begin January 1, 2022. This marks the second delay of the program, which was originally slated to begin on the first of this year. CMS has not yet communicated directly to participants regarding the delay—it was enacted by Congress and not the agency—but we expect CMS to release additional information over the coming weeks and months.

As outlined in our recent blog post, the RO Model requires participants to make extensive operational changes, specifically related to billing, quality tracking, and performance reporting. Organizations will need to update workflows and other processes to comply with these requirements. Understandably, many participants will want to begin working on these changes as soon as possible so they can be ready by January 1, 2022; however, CMS has not yet released specific details regarding these new processes, limiting organizations’ ability to get up and running. Notably, CMS has announced a forthcoming billing guide and accompanying webinar, though neither have been released.

What Now?

While organizations wait for CMS to release additional program information, participants can use this extra time to their advantage.

The RO Model marks a significant departure from CMS’s historical fee-for-service (FFS) payment approach, and we expect it will have a significant financial impact for participants. Therefore, it will be crucial for organizations to implement evidence-based treatment pathways and ensure care is being delivered efficiently and effectively to minimize cost.

As illustrated in the below graphic, we recommend that participants spend time reviewing and updating their care processes and other clinical workflows. The program incentivizes participants to lower their total radiation therapy episode spend through fewer treatment sessions, utilization of less expensive modalities, or both. Adopting techniques that increase efficiency, such as hypofractionation, may help meet these goals.

Next, it will be important for organizations to develop a provider engagement strategy to ensure the care team is equipped to follow guidelines and requirements of the model. Organizations should foster an environment in which the providers are highly engaged and radiation oncologists drive changes to establish new or improved evidence-based protocols.

Looking Ahead

The next several months present an opportunity for participants to get up to speed and ensure they are ready by January 1, 2022. Moreover, due to delayed treatment as a result of the COVID-19 pandemic, we expect a surge in cancer care over the next year; it is crucial that organizations are ready to support the increase in volume along with the new program requirements.

ECG can help you review your current capabilities and ensure you are on track for these significant changes. We have partnered with cancer centers across the country in their care transformation efforts and have helped providers successfully implement other CMS programs, including MSSP, CJR, and BPCI Advanced. We understand the processes required to get your organization ready by the program start date and ensure your program achieves success.

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