How to comply with the CMS RO (RO-APM) Model Requirements

Earlier this September, CMS released their Final Rule detailing a new payment model for Radiation Oncology. Unlike past CMS programs, this new payment model is mandatory for the practices selected (by random zip code) to participate. Along with the potential confusion of new reimbursement levels and procedures, the program comes with a laundry list of requirements to which practices and practitioners must adhere in order to achieve reimbursement. While this model has created controversy in the field, it does represent an opportunity for practices to capture and leverage data to improve care for their patients. It also represents a huge burden for practices selected. Oncora’s software, fortunately, is designed to help practices track and report this information.

When we started Oncora back in 2014, we formed a strategic partnership with MD Anderson to help guide our engineers in building a technology platform capable of capturing structured data in radiation oncology, while simultaneously integrating with EMRs, oncology information systems, and cancer registries. We became obsessed with reducing redundant clicks and inefficient data entry. Physician leaders have collaborated with us during the whole process to ensure our system doesn’t create unnecessary burden on the doctors and care team. Because of this attention to workflow, our software actually reduces the time physicians spend documenting by 67%.Our software has been used to process hundreds of thousands of notes at MD Anderson, and is currently in use by over 100 physicians.

In this blog post, my goal is to provide a resource to practices selected for the RO Model. This post will discuss the “7 Requirements.” I will write additional posts to clarify other points of the RO Model and look forward to feedback from readers. Here are 7 requirements that apply to practices in the RO Model.

  1. Goals of Care: physicians must engage the patient with a goals of care discussion and document the radiation course as either curative or palliative.
  2. Pathways: Physicians must adhere to evidence based pathway (such as an NCCN pathway) or otherwise document and justify their deviation.
  3. Staging: A TNM Stage must be documented by the radiation oncologist at the start of treatment
  4. Performance Status: Physicians must assess and document a quantitative performance status (KPS, ECOG, etc) before treatment
  5. Treatment Summary: Physicians must send referring physician a treatment summary
  6. RO Model Discussion: Physicians must discuss the RO Model with the patient and inform the patient that their cancer center is included in the model
  7. Peer Review: The physician/care team must perform and document peer review on 50% of episodes year 1, increasing every year.

All of the 7 requirements listed above are satisfied by using the Oncora Patient Care and Analytics software to track and organize your cancer center’s data. In fact, a study performed by MD Anderson demonstrated that our tool captured stage 92% of the time and allowed peer review 96% of the time. Because of interoperability with major players in both the EMR and RadOnc software space, we can easily get your practice onboard by the end of the year in time for the program launch on Jan 1, 2021. If you are interested in a demo or wondering if your practice is included in the RO Model, check out our RO Model page for more information.