My admittedly nihilistic concern is that this will marginalize Medicare patients in a much more widespread manner than is seen now. Ostensibly, this is trying to discourage the unscrupulous provider from doing 25 fractions for a single, simple bone met, yes? Alright, so if someone was willing to do that in the current era - commit a fairly egregious sin of fractions to make more money - who knows what else they'll do?
For me, the most obvious choice would be - patient with metastatic disease is referred for bone met palliation. That provider treats with 8x1, because it's the same reimbursement no matter what. In 60 days, patient develops a new lesion which is painful. Patient is re-referred. Based on the current wording, each episode is 90 days with a 28 day "clean period" at the end of the episode. So, is that provider going to rush to see that patient again, knowing they won't be reimbursed FFS? Or is that patient going to get bumped to a much later date, a date when a new episode can be billed? Will there be "second class citizen" patients, where people with private insurance get priority and people with Medicare are seen with less enthusiasm, the easiest/quickest treatment regimen is chosen, and re-referrals are pushed to when a new episode of care can be started?
Pessimistic, I know...but people do what money incentivizes.