News | ASTRO | September 09, 2021

ASTRO Submits RO Model Comment Letters to CMS

Comment letters on the 2022 physician fee schedule and Radiation Oncology Model urge CMS to scale back extreme cuts that jeopardize access to life-saving cancer treatments

Comment letters on the 2022 physician fee schedule and Radiation Oncology Model urge CMS to scale back extreme cuts that jeopardize access to life-saving cancer treatments

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September 9, 2021 — The American Society for Radiation Oncology (ASTRO) submitted two comment letters to the Centers for Medicare and Medicaid Services (CMS) today urging the agency to reconsider policy changes that will result in $300 million in Medicare cuts for radiation therapy services starting January 1, 2022. Thomas J. Eichler, M.D., FASTRO, Chair of the ASTRO Board of Directors, issued the following statement:

"ASTRO submitted comment letters to CMS and asked President Joe Biden to address two proposals that will result in $300 million in cuts to cancer care: $140 million in cuts due to several policy changes in the 2022 Medicare Physician Fee Schedule and cuts of $160 million over 5 years under the mandatory Radiation Oncology Model (RO Model). This double hit will be devastating to our patients and radiation oncology teams, endanger patient access to life-saving treatment and threaten the viability of clinics still reeling from the COVID-19 pandemic. Payment rates for some radiation treatments for breast and prostate cancer will drop by about 13%, for example, and by more than 22% for advanced lung cancer treatment.

We are confused and disappointed that these proposed policies stand in such sharp contrast to President Biden's goals to 'end cancer as we know it' and advance health equity. The excessive cuts will jeopardize patients' ability to get state-of-the-art cancer care close to home, with practices treating underserved populations hit hardest by the cuts. Patients in rural areas, for example, now risk losing access to cancer treatment in their communities, forcing long and expensive travel to receive care. And this comes at a time when cancer incidence rates are rising due to screening delays related to COVID-19.

Radiation oncology is the backbone of the nation's cancer delivery system, providing cost-effective care for more than half of all people diagnosed with cancer. If the cuts are finalized, radiation oncology Medicare reimbursement will have plummeted by 25% since 2012. These proposed cuts to radiation oncology are among the highest of any medical specialty, and our patients will suffer the impact.

ASTRO and the radiation oncology community have proactively pursued value-based reimbursement for radiation oncology that incentivizes high-quality, efficient care while stabilizing payments to ensure patient access to the latest technology in the fight against cancer. We call on the Biden Administration to address the concerns of radiation oncologists across the country and avoid these draconian payment cuts before finalizing the Medicare physician fee schedule and the RO Model.

ASTRO recommends that radiation therapy cancer treatments should be held harmless from payment cuts due to the fee schedule's clinical labor pricing update. We also are asking that the RO Model's discount factors be reduced to 3% to safeguard access to care for patients at the 950 hospitals and community-based clinics required to participate in the model, while ensuring Medicare achieves a reasonable level of savings."

As the radiation oncology community seeks resources and support to improve access and quality for rural and underserved populations, these polices represent a massive step backwards. It is reckless for CMS to propose such a severe decline in reimbursement, particularly during a public health emergency. Medicare should provide stable and predictable reimbursement for care rendered to its beneficiaries."

In July, ASTRO issued a statement calling on President Biden and Congress to intervene on the drastic cuts. The statement emphasized that "ASTRO remains committed to value-based care and to constructively engaging with CMS on reasonable ways to improve these policies" but that "massive cuts such as those proposed by CMS will set us back, not move us forward." If CMS does not reverse course, ASTRO will ask Congress to protect patient access to care via legislation this year.

Congress has long supported radiation oncology's value-based payment goals, passing bipartisan legislation several times to freeze Medicare payments and allow for a smooth transition away from fee-for-service. Bipartisan Members of Congress have written the Centers for Medicare and Medicaid Services (CMS) on multiple occasions to object to these unnecessary radiation therapy payment cuts under the Medicare physician fee schedule and the proposed Radiation Oncology Alternative Payment Model (RO Model).

For more information: www.astro.org

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