Comments on CMS Radiation Oncology and End-Stage Renal Disease Treatment Choices Proposed Rule

The Health Care Transformation Task Force (HCTTF or Task Force) responded to the proposed rule on Radiation Oncology (RO) and End-Stage Rental Disease (ESRD) Treatment Choices (ETC) models (Proposed Rule). The Task Force appreciates that CMS is committed to designing more Advanced Alternative Payment Models (Advanced APMs) that provide opportunities to specialists who currently have few options to participate in value-based payment models. HCTTF applauds CMS for acknowledging this issue and working to create openings for specialists to become Qualifying APM Participants (QPs).

Task Force Response Summary

  1. Advanced Notice. Task Force members request that CMS issue an Interim Final Rule with Public Comment Period— with the selected participants identified in the Interim Final Rule— to ensure meaningful stakeholder engagement and constructive design recommendations in addition to adequate time for providers to prepare for the model. The Task Force recommends CMS include a Performance Year 0 for the RO and ETC models to serve as a baseline measurement and preparation period, similar to the Direct Contracting model. We urge CMS to lower the initial downside risk levels for both programs to encourage participants to commit resources and make early investments to be successful in the model.
  2. Radiation Oncology Model. We request that CMS reevaluate the downside-only design of the discount and withhold process and the penalty for historically-efficient providers to ensure that access to care is not adversely impacted under the model. CMS should offer a solution to support improved coordination between professional and technical component participants that are not Dual participants, including sharing claims data as close to real-time as possible.
  3.  End-Stage Renal Disease Treatment Choices Model. CMS should include appropriate patient acuity and additional adjustments, including those that assess SDOH and unmet social needs, in calculating the home dialysis and transplant rates and issuing the Performance Payment Adjustment. We recommend that CMS lower this rate in the earlier years of the model to encourage meaningful care transformation rather than trivial cost-cutting.


Read the letter here


Letter submitted on September 16th, 2019.