COA Submits Formal Comments to CMS Regarding Proposed Radiation Oncology Model

September 17, 2019

The Community Oncology Alliance (COA) has submitted formal comments to CMS about the agency’s proposed Radiation Oncology Model. In the letter, COA noted that while they appreciate CMS' decision to issue a model that is focused on radiation oncology and to transition providers to value-based care, they also emphasized their opposition to mandatory demonstration projects and expressed concern that the proposed model will create unnecessary burdens and challenges to physicians.

The Community Oncology Alliance (COA) has submitted formal comments to CMS about the agency’s proposed Radiation Oncology Model. In the letter, COA noted that while they appreciate CMS' decision to issue a model that is focused on radiation oncology and to transition providers to value-based care, they also emphasized their opposition to mandatory demonstration projects and expressed concern that the proposed model will create unnecessary burdens and challenges to physicians.

The letter details concerns with multiple areas, including: the timing of the model; the base rate methodology; episode stratification and flexibility; discounts, operations, and cash flow disruption; quality measures and overlap with other models; and the reconciliation process.