Source blog, https://www.discoveriesinhealthpolicy.com/2024/02/nerd-note-cms-deepsixes-advanced.html
####
https://www.perplexity.ai/search/This-letter-and-s9fHjARDT9O6Qe5PLaA_8Q?s=c
This letter and similar complaints led Congress to delay, and CMS to even further delate (to time unknown) the Radiation Oncology care model, which at one time, CMS had been quite ivestment in. Eventually it threw up its hands. What are the stakeholders asking for and what was it seemingly so effective (meaning this particular letter but also no doubt many similar targets and documents around Washington). Consider the fact that CMS often bulldozes through complaints
Sources: Vide infra.
CMS home page
https://www.cms.gov/priorities/innovation/innovation-models/radiation-oncology-model
The Protecting Medicare and American Farmers from Sequester Cuts Act (P.L. 117-71) enacted on December 10, 2021 included a provision that prohibits implementation of the Radiation Oncology Model prior to January 1, 2023. Thus, the RO Model did not begin on January 1, 2022.
On August 29, 2022, CMS published a final rule in the Federal Register, CMS-5527-F2, which finalized delaying the current start date of the RO Model to a date to be determined through future rulemaking. Please reference the final rule CMS-5527-F2....
Answer
The letter sent to CMS on March 1, 2021, by the American College of Radiology (ACR), the American Society for Radiation Oncology (ASTRO), and other stakeholders in the radiation oncology community, outlines several key concerns and requests for changes to the Radiation Oncology (RO) Model. The effectiveness of this letter, and others like it, in influencing CMS's decision to delay the RO Model can be attributed to the detailed articulation of concerns regarding the model's potential impact on patient care, access, and the financial viability of radiation oncology practices. Below are the primary concerns and requests highlighted in the letter:
Answer
Stakeholder Concerns
- Focus on Savings Over Quality: The stakeholders expressed concern that the RO Model prioritizes cost savings over patient access to high-quality care. They argue that the model's design could negatively impact access to care and the quality of services provided.1
- Lack of Transparency and Data Sharing: The letter emphasizes the need for transparency and open dialogue with CMS, particularly regarding the data used to formulate the payment methodology. Stakeholders request access to this data to fully understand the model's impact and identify potential flaws.1
- Payment Methodology Concerns: The letter criticizes the discount factors applied to the Professional Component (PC) and Technical Component (TC) of radiation oncology services, arguing that they do not adequately account for the significant investments required in technology and skilled staff. Stakeholders urge CMS to reduce the discount factors to ensure the financial viability of practices.1
- National Base Rates and Case Mix Adjustment: Concerns were raised about the methodology used to calculate National Base Rates and the inclusion of palliative care cases, which could undervalue the cost of curative cases. Stakeholders also request a COVID-19 adjustment to account for treatment delays and more advanced stage disease presentations.1
- Quality Reporting Requirements: The letter describes the new quality and clinical data collection and reporting requirements as burdensome, especially for small and rural practices. Stakeholders suggest a stepped approach to implementation and accommodations for small and rural practices.1
Requests for Changes
- Reduction of Discount Factors: Stakeholders request that CMS reduce the discount factors to 3% or less to maintain the financial viability of radiation oncology practices.1
- Revaluation of National Base Rates: They urge CMS to revalue the National Base Rates based on cases with curative intent and to establish a separate episode of care for palliative treatment.1
- Transparency and Data Sharing: The letter calls for greater transparency and data sharing regarding the payment methodology and the data used to formulate it.1
- Adjustments for COVID-19 Impact: Stakeholders request adjustments to account for the impact of COVID-19 on patient presentations and treatment delays.1
- Consideration for New Equipment and Service Lines: The letter asks CMS to recognize the need for investments in new technology and service lines, suggesting a rate review mechanism to support these investments.1
Focus on Savings Over Quality: The stakeholders expressed concern that the RO Model prioritizes cost savings over patient access to high-quality care. They argue that the model's design could negatively impact access to care and the quality of services provided
1
.
Lack of Transparency and Data Sharing: The letter emphasizes the need for transparency and open dialogue with CMS, particularly regarding the data used to formulate the payment methodology. Stakeholders request access to this data to fully understand the model's impact and identify potential flaws
1
.
Payment Methodology Concerns: The letter criticizes the discount factors applied to the Professional Component (PC) and Technical Component (TC) of radiation oncology services, arguing that they do not adequately account for the significant investments required in technology and skilled staff. Stakeholders urge CMS to reduce the discount factors to ensure the financial viability of practices
1
.
National Base Rates and Case Mix Adjustment: Concerns were raised about the methodology used to calculate National Base Rates and the inclusion of palliative care cases, which could undervalue the cost of curative cases. Stakeholders also request a COVID-19 adjustment to account for treatment delays and more advanced stage disease presentations
1
.
Quality Reporting Requirements: The letter describes the new quality and clinical data collection and reporting requirements as burdensome, especially for small and rural practices. Stakeholders suggest a stepped approach to implementation and accommodations for small and rural practices
1
.
Requests for Changes
Reduction of Discount Factors: Stakeholders request that CMS reduce the discount factors to 3% or less to maintain the financial viability of radiation oncology practices
1
.
Revaluation of National Base Rates: They urge CMS to revalue the National Base Rates based on cases with curative intent and to establish a separate episode of care for palliative treatment
1
.
Transparency and Data Sharing: The letter calls for greater transparency and data sharing regarding the payment methodology and the data used to formulate it
1
.
Adjustments for COVID-19 Impact: Stakeholders request adjustments to account for the impact of COVID-19 on patient presentations and treatment delays
1
.
Consideration for New Equipment and Service Lines: The letter asks CMS to recognize the need for investments in new technology and service lines, suggesting a rate review mechanism to support these investments
1
.
The effectiveness of this letter in delaying the RO Model likely stems from its comprehensive detailing of the stakeholders' concerns, the broad coalition of organizations involved, and the constructive suggestions for improving the model to better balance cost savings with the quality of patient care. The letter leverages the collective voice of the radiation oncology community, including practitioners, patient advocates, and industry representatives, to make a compelling case for reevaluation and modification of the RO Model
1
2
####
SOURCES
There were 14 sources. They appear in a side panel that is blocked from copy paste.
.
No comments:
Post a Comment
Note: Only a member of this blog may post a comment.