Quality Payment Program: Alternative Payment Models

On September 18, 2020, the Centers for Medicare and Medicaid Services (CMS) released a mandatory Radiation Oncology (RO) Model final rule. Certain RO providers in randomly selected areas are required to participate in the payment model, and these affected practices are listed on CMS’ Participating Zip Code List. The RO Model will include 30% of RO episodes in eligible geographic areas.

The RO Model will qualify as an advanced alternative payment model (APM) under the Quality Payment Program (QPP). The RO Model will require participants to annually certify their intent to use Certified Electronic Health Record Technology (CEHRT), include quality measure performance as a factor when determining payments, and require RO participants to bear more than a nominal amount of financial risk. Within 30 days of the start of PY1, the RO participant would be required to certify its intent to use CEHRT. Participants who do not meet the QP threshold will not qualify for the APM incentive payment and, instead, will be assigned to a MIPS APM.

In December 2021, the RO Model was further delayed by Congressional action. The model was set to begin on January 1, 2022, and end December 31, 2026. Due to the delay, Under the RO Model, Medicare will pay participating providers and suppliers a prospective, modality agnostic, site-neutral, episode-based payment for specified technical and professional RT services furnished during a 90-day episode to Medicare fee-for-service beneficiaries diagnosed with 16 different cancer types. The base payment amounts for RT services included in the model will be the same for hospital outpatient departments (HOPDs) and freestanding radiation therapy centers. The ACR continues advocacy efforts to improve the payment methodology of the model.

• ACR submits comments on indefinite delay
• RO Model Website
• RO Model Fact Sheet
• RO Model FAQs
• ACR RO Model Final Rule Initial Summary
• RO Model Final Rule
• Participating Zip Code List
• ACR Urges CMS to Delay RO Model, Reduce Cuts
• ACR Urges White House to Stop Cuts Facing Radiation Therapy (September 2021)

Questions regarding the RO Model may be submitted to economics staff via Smartsheet.

The Medicare Shared Savings Program (MSSP) is an alternative payment model that encourages groups of doctors, hospitals, and other health care providers to come together as an ACO to give coordinated, high quality care to their Medicare beneficiaries. CMS is encouraging providers to participate in ACOs through the MSSP, which allows for different participation options/tracks that best fit an organization. Among these different levels and tracks, there are several of which qualify as Advanced APMs.

• MSSP Overview 
• MSSP Levels and Tracks  

The BPCI Advanced Model aims to encourage clinicians to adopt best practices, reduce expenditures, and improve quality throughout a clinical episode. This model qualifies as an advanced APM, operates under a total-cost-of-care concept, and eligible inpatient clinical episodes included in the model are stroke and simple pneumonia.

• BPCI Advanced Website

• List of APMs in the QPP 
• Center for Healthcare Quality and Payment Reform: The Payment Reform Glossary
• JACR: Radiology in Pioneer Accountable Care Organizations: Much Ado About Nothing?
• ACR White Paper: Strategies for Radiologists in the Era of Health Care Reform and Accountable Care Organizations: A Report From the ACR Future Trends Committee
• MACRA, Alternative Payment Models, and the Physician-Focused Payment Model: Implications for Radiology
• Expanding Role of Certified Electronic Health Records Technology in Radiology: The MACRA Mandate
• Alternative Payment Models in Radiology: The Legislative and Regulatory Roadmap to Reform
• Foundational Changes Critical to Payments for Radiology Services