The American Hospital Association is urging CMS to make its proposed radiation oncology alternative payment model voluntary and to delay the model's start date past April 1, 2020 "until at least 12 months after the final rule for this model is published."
Representatives with the association made the recommendations in comments submitted Sept. 16 about CMS' proposed model, which would test prospective, episode-based payments to physician group practices, hospital outpatient departments and freestanding radiation therapy centers for 17 cancer types. Under the model, payments would cover 90-day care episodes, and the model would be tested in randomly selected core-based statistical areas of the U.S.
Hospitals said the federal government should make the model voluntary for providers because "hospitals and health systems that would be required to participate in this model are of many different sizes and types and are at different points in the process of transitioning to value-based care."
"They should not be required to participate in such a complicated program, which includes 17 different types of cancer, if they do not believe it will benefit the patients they serve. Moreover, other providers that may have the systems in place to excel under this new model could be excluded based on geographic location," they added.
The American Hospital Association said CMS should also delay the start date of the model due to the time required of hospitals to ensure compliance with the model's coding and billing requirements.
The association said the proposed Jan. 1, 2020, and April 1, 2020, start dates do not provide enough time "to undertake this work and put in place the care processes and procedures necessary to achieve success in the program."
But delaying the start date past April 1, 2020 "until at least 12 months after the final rule for this model is published," hospitals said, would help provide ample time for participants.
The American Hospital Association also called on CMS "to balance the risk versus reward equation much more appropriately" in the model.
Read the association's full letter to CMS here.
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