Analysis: Timeline for CMS’s mandatory radiation oncology model appears to slip

• The government appears to be walking back its plan to finalize the CMS proposed mandatory radiation oncology alternative payment model, according to a Healthcare Dive article.
• CMS was targeting an implementation date as early as Jan. 1, but the new regulatory agenda lists July 2022 as a target, according to Healthcare Dive.
• CMS says it does not intend to delay publishing the regulation if it is able to do so sooner.

Healthcare Dive is reporting that “months after the medical device industry slammed CMS’ proposed mandatory radiation oncology alternative payment model (RO-APM) as too aggressive, the government appears to be walking back its plan to finalize the regulation, placing it on its long-term agenda.

CMS originally estimated the mandatory model would save up to $260 million over a five-year period.

Originally, the agency was targeting an implementation date as early as Jan. 1, but the new regulatory agenda lists July 2022 as a target. It’s unclear what the timeline for the final rule will be.

CMS says it does not intend to delay publishing the regulation if it is able to sooner. The July proposal to establish a bundled payment system for 40% of Medicare RO episodes was met with concern from both physicians and companies who sell the equipment used to provide treatment.”

Takeaway

Given the complexity of the model, limited or no upside for providers who are efficient, and pushback from a wide range of stakeholders, it’s not surprising that the Centers for Medicare & Medicaid Innovation (CMMI) has slowed its pace on this. The final rule isn’t even at the Office of Management and Budget, so I would anticipate that it will be summer of 2020 at the earliest before we see it.

Beyond technical issues, the ongoing leadership transition at CMMI may further delay the final rule and start date. This is pure speculation, but the leadership transition may also open the door to significant changes in the model like a shift from mandatory to voluntary (or similar to Comprehensive Care for Joint Replacement model, a reduction in the number of mandatory markets while opening the model up to voluntary participation) as was advocated for by the American Medical Association and others in their comments.