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2022 Final Payment Rules Yield Few Changes, Emphasizing Need for Legislative Solution

November 2, 2021

Radiation oncology is still facing significant payment cuts following this evening’s issuance of the Centers for Medicare and Medicaid Services (CMS) 2022 Medicare Physician Fee Schedule (MPFS) and the Hospital Outpatient Prospective Payment System (HOPPS) final rules.

The RO Model is now expected to save $150 million over 5 years, down slightly from $160 million over 5 years in the most recent proposal. The discount factors remain unchanged at 3.5% off the Professional Component and 4.5% off the Technical Component.

The Agency is adopting an extreme and uncontrollable circumstances (EUC) policy associated with the COVID-19 PHE that will grant RO Model participants flexibility on quality measures and clinical data elements (CDE) reporting requirements, as well as make optional the requirements associated with participation in an AHRQ-listed patient safety organization (PSO) and Peer Review in the first performance year (PY1). According to the final rule, the EUC policy will provide all RO Model participants with the option to collect and submit quality measures and CDEs in PY1. As a result, the 2% quality withhold will be removed from the payment methodology. Those RO Model participants that submit the quality measures and CDEs will still be eligible for Advanced APM status and the Advanced APM 5% bonus on professional component services.

In the MPFS, CMS modified the impact of the Clinical Labor Price input update on radiation oncology from 4% to 3% overall. The Agency also will phase in the policy over a four-year period, resulting in a 1% cut to radiation oncology payments in the first year. There were no changes to the Conversion Factor, and the Agency will move forward with the last year of the equipment and supplies pricing update, which was initiated in 2018. The overall impact to radiation oncology is a cut of 7.75%, when accounting for the expiration of the 3.75% conversion factor increase, down from the 8.75% cut in the proposed rule.

Additional analysis of specific code level impact and detailed summaries of both rules will be issued in the coming days. While ASTRO is pleased with some small and short-term improvements, we remain concerned that radiation oncology continues to bear the brunt of payment cuts that will jeopardize access to treatment and will continue to advocate for legislative changes to support the specialty. Read ASTRO’s official initial statement on the rules.