Mandatory Radiation Oncology Bundle to Begin on January 1, 2021
On September 18, 2020, CMS finalized a proposed rule to transition the current fee-for-service (FFS) payment methodology for radiation therapy services to a value-based payment arrangement. According to CMS, the goal of this model is to “test whether bundled, prospective, site neutral, modality agnostic, episode-based payments to physician group practices, hospital outpatient departments, and freestanding radiation therapy centers for radiotherapy episodes of care reduces Medicare expenditures, while preserving or enhancing the quality of care for Medicare beneficiaries.”
The final rule comes on the heels of the Comprehensive Care for Joint Replacement program’s three-year extension and recent announcement that the voluntary Bundled Payments for Care Improvement Advanced program will become mandatory in 2024.
Providers located in the Radiation Oncology (RO) Model-affected ZIP codes will enter the five-year program on January 1, 2021. For the 16 different cancer types included in the program, providers will receive prospective, modality agnostic, episode-based payments in a site-neutral manner. Half of the pre-established payment will be made at the initiation of the episode, and the remainder will be paid at the end of the 90-day episode.
Below are key takeaways:
- Five-year mandatory participation for radiation therapy (RT) providers and suppliers located in the affected ZIP codes
- Covers 16 different cancer types
- Affects beneficiaries who are eligible for Medicare Part A and enrolled in Medicare Part B and have traditional Medicare FFS as primary insurance
- Participant-specific, site-neutral payments are determined based on national base rates, trend factors, and adjustments for each RO participant’s case-mix and geographic location
- Payment to be split into two components—professional and technical
- Payment will be automatically reduced by a discount factor, which may be earned back
- Exclusions for critical access hospital providers, ambulatory surgery centers, and certain providers with fewer than 20 impacted cancer episodes in the prior year
- Defined quality metrics for participants and eligibility for Advanced Alternative Payment Model designation
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BKD has experience assisting hospitals and clinicians with bundled payment arrangements. If you have questions regarding the RO bundle, reach out to your BKD Trusted Advisor™ or submit the Contact Us form below.
This information is only valid as of the date of this publication and is subject to change. The content was presented for illustrative purposes and your information only. Applying this information to your situation requires careful consideration of facts, circumstances, and timing of requirements. Consult your BKD advisor or legal counsel to apply to your unique situation and circumstances.