CMS has been studying our literature like a first-year rad onc resident... probably with the same level of intellectual nuance...
Aligning Payments to Quality and Value, Rather than Volume
For some cancer types, stages, and characteristics, a shorter course of RT treatment with more radiation per fraction may be appropriate. For example, several randomized controlled trials have shown that shorter treatment schedules for low-risk breast cancer yield similar cancer control and cosmetic outcomes as longer treatment schedules. As another example, research has shown that radiation oncologists may split treatment for bone metastases into 5 to 10 fractions, even though research indicates that one fraction is often sufficient. In addition, recent clinical trials have demonstrated that, for some patients in clinical trials with low- and intermediate-risk prostate cancer, courses of RT lasting 4 to 6 weeks lead to similar cancer control and toxicity as longer courses of RT lasting 7 to 8 weeks (EDITORS NOTE: I'M LOOKING AT ME). Based on this review of claims data, we believe that the current Medicare FFS payment systems may incentivize selection of a treatment plan with a high volume of services over another medically appropriate treatment plan that requires fewer services. Each time a patient requires radiation, providers can bill for RT services and an array of necessary planning services to make the treatment successful. This structure may incentivize providers and suppliers to furnish longer courses of RT because they are paid more for furnishing more services. Importantly, however, the latest clinical evidence suggests that shorter courses of RT for certain types of cancer would be equally effective and could improve the patient experience, potentially reduce cost for the Medicare program, and lead to reductions in beneficiary cost-sharing. There is also some indication that the latest evidence-based guidelines are not incorporated into practices’ treatment protocols in a timely manner. For example, while breast cancer guidelines have since 2008 recommended that radiation oncologists use shorter courses of treatment for lower-risk breast cancer (3 weeks versus 5 weeks EDITORS NOTE: I'M LOOKING AT YOU BREAST BOOSTERS), an analysis found that, as of 2017, only half of commercially insured patients actually received the shorter course of treatment.
How it works...
Model Design
The proposed RO Model would take significant steps towards making prospective, episode-based payments in a site-neutral manner for 17 different cancer types. The Model would further the Innovation Center’s efforts to test site-neutral models and to test patient-centered, physician-focused models that provide an opportunity for physicians to participate in an Advanced Alternative Payment Model (APM) under the Quality Payment Program (QPP.). The Model would also be expected to improve the beneficiary experience by rewarding high-quality, patient-centered care and would incentivize high-value RT that results in better patient outcomes.
The RO Model would require participation from RT providers and suppliers that furnish RT services within randomly selected Core Based Statistical Areas. Beneficiaries would still be able to receive care from any provider or supplier of their choice. Model participants treating beneficiaries with one of the included cancer types would receive prospective, episode-based payment amounts for RT services furnished during a 90-day episode of care, instead of regular Medicare FFS payments, throughout the model performance period.
Model episode payments would be split into a professional component (PC) payment, which is meant to represent payment for the included RT services that may only be furnished by a physician, and the technical component (TC) payment, which is meant to represent payment for the included RT services that are not furnished by a physician, including the provision of equipment, supplies, personnel, and costs related to RT services. This division reflects the fact that RT professional and technical services are sometimes furnished by separate providers or suppliers.
The incentive structure for bundling almost assures antagonism and in-fighting between specialties. Am I wrong about this? Sad, as we are on the bottom of the totem pole of hospital power.
"When I first became the chairman of a Department of Radiation Oncology, the chairman of surgery referred to radiation oncology as a “clinical catfish: the bottom-feeding garbage-eater at the end of the clinical referral chain.'"
- Ed Halperin M.D.
