Radiation Oncologists Await HHS Details on Mandatory APM

Radiation oncologists are leery of mandatory alternative payment models put forward by HHS, but they'll withhold criticism until they see the proposed model.

Radiation oncologists have been champions of alternative payment models, but not necessarily when they are mandatory.

So, there were mixed reactions when Health and Human Services Secretary Alex Azar strongly suggested that radiation oncologists would soon be placed in a mandatory APM. 

"We have some reservations about moving forward in a mandatory fashion and really need to learn more about what the secretary has in mind," says Dave Adler, vice president for advocacy at the American Society for Radiation Oncology.

"Our biggest concern would be going 'full mandatory,' where every radiation oncologist is required to participate in this model on Day One," Adler says. "That may be too much and too fast. But it'd be premature to say we object to mandatory model without having those details."

In a speech earlier this month, Azar signaled a shift in HHS policy when he said his department has "reexamined" last year's decision to pull back on episode payment models before they were launched.

"We intend to revisit some of the episodic cardiac models that we pulled back, and are actively exploring new and improved episode-based models in other areas, including radiation oncology," Azar said. "We're not going to stop there: We will use all avenues available to us—including mandatory and voluntary episode-based payment models."

Adler says Azar's comments were not particularly surprising because he's been talking about mandatory APMs since his confirmation hearings in the Senate last January.

In April 2017, ASTRO submitted a model APM to the Center for Medicare & Medicaid Innovation. Adler says the big question now is how much of that proposal HHS will incorporate into any mandatory APM it rolls out.

"It's probably not lost on them that the radiation oncology community has rallied around this model," Adler says. "We think it's a strong opportunity to improve quality and reduce costs in a way that's meaningful for radiation oncology practices and their patients."

First and foremost, Adler says ASTRO's APM proposal calls for physician autonomy.

"When it comes to the payment incentives, when it comes to quality measures, it's got to be things that are in control of the radiation oncologist," he says. "We don't want them to be held accountable for things outside of their control."

Whatever APM is put forward, Adler says there will be little ramp up time for implementation, which is expected to begin on Jan. 1, 2020.

"A lot of the path that got us here has been driven by Congress through legislation that has frozen key radiation therapy payments for the last couple of years to allow CMS time to work with the community to come up with an APM," Adler says.

"That legislation was extended earlier this spring to go through the end of 2019. A lot of stakeholders, ASTRO included, hope we could have this model up and running before no later than the expiration of that legislative deadline," he says.

Adler says ASTRO has gotten good feedback for its APM model from CMMI.

"We have had every indication that they've looked closely at our model, asked a lot of good questions to understand the model and how radiation oncology practices work, so we've really been impressed with commitment at CMMI to learn about the specialty and our model," he says.

"We want to hear the administration out. We want to see what they had in mind, not only on mandatory but for all aspects of the model," he says. "We know what we've proposed, but we don't know exactly what CMS has in mind so we want to ensure that we have ample opportunity to review all aspects of the model and then to consider the pros and cons and look at mandatory in the context of all aspects."