CHA submitted comments on the proposed mandatory Radiation Oncology Model (RO Model) detailed in the specialty care models proposed rule issued by the Centers for Medicare & Medicaid Services (CMS). In the letter, CHA warns that there could be unintended consequences hindering access to oncology care in California if the RO Model is not modified. Comments are due to CMS by 2 p.m. (PT) on Sept. 16. Members are encouraged to use the draft to submit their own comments.
In the letter, CHA asks CMS to:
- Delay implementation of the RO Model for at least 12 months from the issuance of the final rule.
- Consider a phased approach to implementation, so hospitals that are ready may opt in voluntarily.
- Consider a retrospective model if CMS proceeds with implementation.
- Modify the efficiency and discount factors.
- Modify the additional proposed documentation requirements to include only the most clinically relevant information for data collection in performance year two and beyond.
- Make participant level data available as soon as possible to assist the field in understanding CMS’ proposals and begin to consider the operational issues that must be addressed prior to implementation.