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Internal CMS Transmittal Lays Out Radiation Therapy Bundle Plan
February 13, 2019
CMS
in an internal transmittal to contractors dated Feb. 15 lays out a proposal for a prospective bundled payment radiation oncology model that would replace fee-for-service payments in randomly selected geographic areas, a move that comes after HHS Secretary Alex Azar indicated the agency was eying a mandatory radiation therapy demonstration.
A CMS spokesperson told
Inside Health Policy the document was inadvertently posted and is for internal planning purposes at this point.
“CMS has and will continue to conduct extensive and ongoing stakeholder engagement regarding a potential radiation oncology bundle,” the agency spokesperson said Feb. 13.
The American Society for Radiation Oncology is happy an alternative pay model is moving forward.
“We are pleased that CMS continues to make progress on an advanced alternative payment model for radiation oncology. We also appreciate that CMS takes stakeholder input seriously and that the agency has provided opportunities for ASTRO and other stakeholders to share our input. We remain committed to working with CMS on policies that will ensure payment stability for radiation oncology practices and the highest quality of care for patients,” said Anne Hubbard, ASTRO’s director of health policy.
Azar in November indicated that CMS was actively exploring a possible mandatory radiation therapy demonstration. Radiation oncologists at the time
raised concerns about making such a demo mandatory.
A November analysis from the Advisory Board says the 2015 Patient Access and Medicare Protection Act paved the way for a radiation oncology advanced payment model by freezing payments for freestanding radiation therapy services until this year. The analysis adds that CMS, Congress and the providers were supposed to agree on an APM by that point.
The final physician fee schedule rule for 2019 was estimated to cut payments by 1 percent for radiation oncology in 2019, which is less than the proposed rule initially called for, according to an ASTRO summary.
The transmittal says CMS will allow for “the continuation of discussions and development of business requirements for the implementation of the Prospective Bundled Payments for Radiation Oncology (RO) Model,” and says the Medicare Administrative Contractors should expect to participate in conference calls on the proposal.
CMS is proposing bundled payments for all included radiation therapy services, instead of using Medicare fee-for-service payments, provided in certain randomly selected geographic areas, the transmittal states. The agency would like to include 17 types of cancer in the model.
The agency envisions a 90-day episode for the bundle. The first half of the payment would come when providers bill an initial code triggering the model, and the second half would come when a modified version of the code is billed to trigger the end of the episode. CMS says payment for the technical component would be made through either the physician fee schedule or the hospital outpatient pay system, as both freestanding radiation therapy centers and hospital outpatient departments would participate.
Following a 90-day episode, CMS says participants would be able to bill radiation therapy services as fee-for-service for the same beneficiary for 28 days before a new episode could be triggered.
If a beneficiary dies or enters hospice once the episode has been initiated, providers would still get full payment under CMS’ proposal, even if the beneficiary didn’t finish treatment.
“CMS shall provide further billing instructions to participants through sub regulatory channels of communication, including the Medicare Learning Network (MLN Matters) publications and model-specific webinars,” the transmittal says. --
Michelle M. Stein(
[email protected]) and
John Wilkerson(
[email protected])
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