07 Apr The Task Force Provides Input to CMMI on the Radiation Oncology Model
The Health Care Transformation Task Force (HCTTF or Task Force) wrote to the Center for Medicare and Medicaid Innovation (CMMI) regarding the Radiation Oncology Model. The Task Force is pleased with CMMI’s ongoing efforts to drive health care payment reforms and regular engagement with the Task Force on issues of model design and implementation. The Task Force supports CMMI’s mission to reform the health care system and submitted the following feedback in hopes of addressing HCTTF member concerns with the design of the Radiation Oncology (RO) model.
Task Force Letter Summary
- Pricing methodology: The Task Force Encourages CMS to (1) reevaluate the downside-only design of the discount and withhold process and consider incorporating upside incentives for improving quality and efficiency, (2) incorporate a glide path structure that allows providers with less APM experience to accept increasing risk over time, and (3) evaluate the potential adverse impacts on historically efficient providers and providers serving under-resourced communities to ensure that access to care is not adversely impacted under the model
- Coordination between separate episode components: HCTTF believes the RO model is currently designed could create disincentives for the use of guideline concordant, multi-modality treatments in situations where multiple physicians or sites of service are involved in a patient’s treatment. CMS should offer a solution to support the delivery of guideline concordant care and improved coordination, including ensuring that the model makes proper payments for the services delivered and sharing claims data as close to real-time as is possible.
- Quality measures and withhold: HCTTF supports efforts to identify and test metrics that measure performance improvement and patient experience, however, CMS has not clearly stated a payment or quality rationale for the RO model reporting requirements. Given the reporting burden and expense of extracting the requested data, HCTTF does not believe CMS should mandate that participants report clinical data elements.