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Your 4-step guide to prepare for a mandatory radiation oncology bundle


Way back in 2015, the Patient Access and Medicare Protection Act set the stage for a radiation oncology alternative payment model (APM). It froze payments for freestanding radiation therapy services until January 1, 2019, at which point CMS, Congress, and the provider community were supposed to agree to an alternative APM.

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While medical oncology gets the lion's share of attention due to jaw-dropping drug prices and reports of unwarranted variation, radiation oncology is a more attractive target for APMs for many reasons. In contrast to chemotherapy, it tends to have more predictable and clear treatment endpoints, relatively standardized and fewer unexpected costs, and the potential to reduce costs by changing clinical practice (e.g., use of hypofractionation).

Oncology community concerned about 'mandatory' bundle

HHS Secretary Alex Azar's announcement was surprising as it deviates from the Trump administration's previous stance on mandatory payment models under former HHS Secretary Tom Price. In 2017, CMS eliminated three planned mandatory APMs for heart attack treatment, bypass surgery, and hip and femur fracture treatments.

And the announcement concerned many in the oncology field. Both the American Society for Radiation Oncology (ASTRO) and American Society of Clinical Oncology (ASCO) immediately released statements expressing concern that this mandatory program would negatively affect patient access to care.

No matter what happens, start preparing now

While we wait to learn the details of the bundle, cancer programs need to start developing strategies to decrease costs and improve quality. Best-in-class radiation oncology programs are doing the following:

  1. Ensuring adherence to evidence-based care: Encourage the development of more clinical evidence and rapidly incorporate new information on cost and patient outcomes into treatment protocols. After implementing clinical pathways, one cancer program increased its use of hypofractionation for breast patients from 8% to 77% in just three years.

  2. Facilitating shared decision making: Engage patients in treatment decisions that factor in costs to the patient, outcomes, and their goals for care. Jefferson Health's decision counseling program helps low-risk prostate cancer patients select the treatment that aligns with their goals. 83% of participants in a pilot chose active surveillance.

  3. Finding ways to improve safety: Seek new opportunities to improve safety and compliance with processes and protocols. Northwell Health developed its Smarter Radiation Oncology™ program consisting of evidence-based pathways, daily peer review to ensure consensus on directives and contours, and rescheduling requirements designed to ensure every step occurs sequentially. Over a 22-month period, their peer review corrected issues in 25% of cases, saving time in the long run by reducing the number of treatment plans that require modification later on.

  4. Revamping investment strategy: Invest in technologies that promote higher-value care. In the past, capital equipment's ROI was primarily determined by its impact on cash flow and capacity. These are still important, but you also need to consider nontraditional returns, such as cost avoidance resulting from reduced toxicities.


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