ROCR Town Hall/Webinar Discussion

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Have at it everyone

From my brief runthrough:
- accreditation necessary, via ASTRO, ACR, or ACRO
- payments neutralized across sites of service
- there is an inflationary adjustment added
- transportation payment for health equity
- I'm not finding a proton carveout but I haven't fine-tooth combed it

I just quickly skimmed it......re: protons....

this is all I see on protons (from page 29) in reference to some sort of 7-year period/re-evaluation...I can't tell if protons are included now and may come out later, or if not included now but may be put in later.

1715867610697.png

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this bolded above im not a fan of. If they are going to demand accreditation then they should allow for other entities to get involved to introduce more competition/variability/etc...otherwise those three can control prices and have power over things like supervision, staffing, etc.

At least there are three options as opposed to one, and if these three act together to control prices, that would be illegal collusion in a market. I'm not saying they won't do that, but at least technically they shouldn't.
 
Accreditations are completely idiotic - waste of time and money
Subpar doctors will do subpar things even with the ABR/ASTRO/ACRO stamp on their building
 
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I just quickly skimmed it......re: protons....

this is all I see on protons (from page 29) in reference to some sort of 7-year period/re-evaluation...I can't tell if protons are included now and may come out later, or if not included now but may be put in later.

View attachment 386811
That was my assessment of this section, which I probably found like you did (control F "protons" and this was all that popped up). All it's doing is asking the gov't to reassess the impact at 7 years.
 
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Have at it everyone

From my brief runthrough:
- accreditation necessary, via ASTRO, ACR, or ACRO
- payments neutralized across sites of service
- there is an inflationary adjustment added
- transportation payment for health equity
- I'm not finding a proton carveout but I haven't fine-tooth combed it
Da carveouts. Unconscionable. 10 year exclusion from time of implementation

18 ‘‘(B) EXCLUSIONS.—Such term does not19 include—20 ‘‘(i) during the period beginning on the date on which the regulation issuedpursuant to subsection (a)(1) become effective and ending on the date that is 10 years after such date, brachytherapy, proton beam radiation therapy, intraoperative radiotherapy, superficial radiation therapy, hyperthermia, and therapeutic radiopharmaceuticals;‘‘(ii) inpatient radiation therapy services furnished in a subsection (d) hospital or ambulatory surgical center;7 ‘‘(iii) radiation therapy services furnished in cancer hospitals that are exempt from the hospital outpatient prospective payment system under section (t);11 ‘‘(iv) physician services that are furnished or supervised by the physician furnishing radiation therapy or by another physician, such as cancer surgeries, chemo15 therapy, and other services; or16 ‘‘(v) physician services that are fur17 nished using technology represented by18 Healthcare Common Procedure Coding19 System codes that are not included in the20 M-code national base rates identified in21 table 75 (including in HCPCS Codes for22 radiation therapy services and supplies) of23 the Federal Register on November 16,24 2021, 86 Fed. Reg. 63485, 63925.
 
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Da carveouts. Unconscionable. 10 year exclusion from time of implementation

18 ‘‘(B) EXCLUSIONS.—Such term does not19 include—20 ‘‘(i) during the period beginning on the date on which the regulation issuedpursuant to subsection (a)(1) become effective and ending on the date that is 10 years after such date, brachytherapy, proton beam radiation therapy, intraoperative radiotherapy, superficial radiation therapy, hyperthermia, and therapeutic radiopharmaceuticals;‘‘(ii) inpatient radiation therapy services furnished in a subsection (d) hospital or ambulatory surgical center;7 ‘‘(iii) radiation therapy services furnished in cancer hospitals that are exempt from the hospital outpatient prospective payment system under section (t);11 ‘‘(iv) physician services that are furnished or supervised by the physician furnishing radiation therapy or by another physician, such as cancer surgeries, chemo15 therapy, and other services; or16 ‘‘(v) physician services that are fur17 nished using technology represented by18 Healthcare Common Procedure Coding19 System codes that are not included in the20 M-code national base rates identified in21 table 75 (including in HCPCS Codes for22 radiation therapy services and supplies) of23 the Federal Register on November 16,24 2021, 86 Fed. Reg. 63485, 63925.
There you go.

The people writing the bill excluded themselves from any outcome related to this. No skin in the game.
 
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I found a pretty good lobbyist that would be willing to fight against this. Would others be willing to chip in?
absolutely; some kind of go fund me would also make a performative statement to asto and the field., At the very least I will reach out to my congressman. Is there anyway to conduct a poll on this site to demonstrate how many of us are against this?
 
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Glad they excluded superficial XRT to protect the dermatologists.

They will continue to bill their 34 treatments, daily IGRT, and daily follow up visits under the old FFS model and make 25k per 1cm BCC.
 
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Glad they excluded superficial XRT to protect the dermatologists.

They will continue to bill their 34 treatments, daily IGRT, and daily follow up visits under the old FFS model and make 25k per 1cm BCC.

I get why big rad onc would want protons excluded...but why the superficial thing?
Is that just to keep the derm lobby out of this?

That's nuts.
 
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Unconscionable. No field tries to screw private practice more than ours. Of course they carve out their centers and protons, but this Derm carve out is next level diabolical because they knew Derm lobbyists would get this bill canned. They hate private practice radiation oncologists so much that they would pass a bill that appeases the most unscrupulous private practitioners in another field just to screw us. Diabolical. We desperately need a society that looks out for private practice, we are a large portion of the field.
 
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diabolical
Yeah...the rapidly expanding abuse of "image guided" superficial XRT for non-melanomatous skin cancer is a real problem. It is extraordinarily low value and worse than what most of us do (non-image guidance electron therapy) from a fundamentals standpoint most of the time.

Glad that ASTRO didn't want to touch that.
 
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Accreditations are completely idiotic - waste of time and money
Subpar doctors will do subpar things even with the ABR/ASTRO/ACRO stamp on their building

Just when I thought ASTRO couldn't sink any lower, they pull this crap. Unbelievable.

It's like they are intentionally trying to shut down every single doc rural site in the country, and there are a lot of them. How many of these are accredited or could even reasonably become accredited?

Someone has a hard on for direct supervision, and that is still what this is about.

No way this can stand.
 
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Unconscionable. No field tries to screw private practice more than ours. Of course they carve out their centers and protons, but this Derm carve out is next level diabolical because they knew Derm lobbyists would get this bill canned. They hate private practice radiation oncologists so much that they would pass a bill that appeases the most unscrupulous private practitioners in another field just to screw us. Diabolical. We desperately need a society that looks out for private practice, we are a large portion of the field.
It's not even just private practice. This is screwing solo hospital employed docs. Literally all ASTRO cares about protecting are the academic systems. They want a cartel where every LINAC is controlled by an academic system with new grads rotated out to the cornfields to directly supervise. Private equity leveraged buyouts would be preferable to this.
 
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Da carveouts. Unconscionable. 10 year exclusion from time of implementation
10 years for Big Rad Onc to marginalize, bankrupt, and absorb Little Rad Onc. Then they acquire all the broken pieces at pennies on the dollar and all of a sudden:

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Private equity leveraged buyouts would be preferable to this.
The same types of people run big academia and private equity. Schools are now there to support endowments, not the other way around. Faculty have known this (particularly in the humanities and basic sciences). Medical faculty are the last to put up a fight, because they are the best compensated. Medical faculty leadership may well be considered rent seekers in this fiasco.
 
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Is that just to keep the derm lobby out of this?
Step Brothers Yep GIF by reactionseditor


It's crazy that they wouldn't want to be included in this though, as it's so good for everyone. Protons too. After all, they're expensive and this stabilizes payment. Much important.
 
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The same types of people run big academia and private equity. Schools are now there to support endowments, not the other way around. Faculty have known this (particularly in the humanities and basic sciences). Medical faculty are the last to put up a fight, because they are the best compensated. Medical faculty leadership may well be considered rent seekers in this fiasco.
Correct - academic institutions are now essentially hedge funds which offer courses on the side

Edit: This is as good a place as any to point out that what we have here is an absolutely classic case of regulatory capture.
 
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Correct - academic institutions are now essentially hedge funds which offer courses on the side
Yup.

Mucho "Mission Driven".

Everyone is trying to squeeze the last buck out of this house of cards before the guillotines roll into the streets.
 
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Yup.

Mucho "Mission Driven".

Everyone is trying to squeeze the last buck out of this house of cards before the guillotines roll into the streets.
I'm sure student loan forgiveness will fix all of it. Just take all the pretense away that the tax base is being directly funneled to their endowments giving them carte blanche to charge whatever they want for tuition and increase their administrative bloat exponentially.
 
Accreditation is not mandatory. 1% cut to technical only, if you do not obtain in first 3 years.

Small suppliers and providers (whatever that means) potentially exempt from accreditation and can do external audit instead, and are also eligible for an additional 0.25% increase without risk of penalty.

Site neutrality finally. Exempt from the yearly whittling down of a few percent. Payments for transportation.

Seems like... Some good things?

I'm no fan of Astro and also all the carveouts make me give this the hard side eye, but I actually think this will dramatically help out practice. We bill MPFS freestanding rates and aggressively hypofractionate.

Tell me what I'm missing?
 
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Accreditation is not mandatory. 1% cut to technical only, if you do not obtain in first 3 years.

Small suppliers and providers (whatever that means) potentially exempt from accreditation and can do external audit instead, and are also eligible for an additional 0.25% increase without risk of penalty.

Site neutrality finally. Exempt from the yearly whittling down of a few percent. Payments for transportation.

Seems like... Some good things?

I'm no fan of Astro and also all the carveouts make me give this the hard side eye, but I actually think this will dramatically help out practice. We bill MPFS freestanding rates and aggressively hypofractionate.

Tell me what I'm missing?
Not a huge fan of accreditation, but I think it won't be too onerous.

Agree some good things. Case based payments are ideal IMO. The reduction in duration of encounter to 30 days for bone and brain mets is prudent (and much better than 90 days).

In many cases, it's not clear to me that hypofractionation is actually helping the patient. The incentives are away from more protracted and often less toxic treatment in some circumstances. It is what it is.

The carve outs are the main thing however. They are not defensible and I have not heard a rational defense (just an argument from authority). The excess costs of care from PPS exempt places and proton places could have been assumed as judicious at present and factored into total cost models going forward. They chose to believe that they will achieve significant cost savings on the backs of community care while perpetuating low value care at name brand academic and proton centers. It totally sucks.
 
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Small suppliers and providers (whatever that means) potentially exempt from accreditation and can do external audit instead, and are also eligible for an additional 0.25% increase without risk of penalty.
An external audit by whom and to what standards? Surely ensuring direct supervision at all times.
 
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Not a huge fan of accreditation, but I think it won't be too onerous.

Agree some good things. Case based payments are ideal IMO. The reduction in duration of encounter to 30 days for bone and brain mets is prudent (and much better than 90 days).

In many cases, it's not clear to me that hypofractionation is actually helping the patient. The incentives are away from more protracted and often less toxic treatment in some circumstances. It is what it is.

The carve outs are the main thing however. They are not defensible and I have not heard a rational defense (just an argument from authority). The excess costs of care from PPS exempt places and proton places could have been assumed as judicious at present and factored into total cost models going forward. They chose to believe that they will achieve significant cost savings on the backs of community care while perpetuating low value care at name brand academic and proton centers. It totally sucks.

Large academic hospital systems should have lower costs than smaller community practices due to economies of scale. Even if they have higher costs, why should the government reward inefficiency with higher payments? The fact that they carved themselves out of the very bill they wrote is a textbook example of regulatory capture, and it is of course indefensible.
 
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Accreditation is not mandatory. 1% cut to technical only, if you do not obtain in first 3 years.

Small suppliers and providers (whatever that means) potentially exempt from accreditation and can do external audit instead, and are also eligible for an additional 0.25% increase without risk of penalty.

Site neutrality finally. Exempt from the yearly whittling down of a few percent. Payments for transportation.

Seems like... Some good things?

I'm no fan of Astro and also all the carveouts make me give this the hard side eye, but I actually think this will dramatically help out practice. We bill MPFS freestanding rates and aggressively hypofractionate.

Tell me what I'm missing?
ROCR sets conditions for a huge competitive advantage for large centers, pps and proton, to expand and bring more patients under their high cost umbrella. Ultimately, payments are very disconnected from CMS rates. Almost zero patients have pure medicare. Hospital negotiated prices are going up not down. If this was so great for our reimbursement, why would they exempt themselves.
 
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Accreditation is not mandatory. 1% cut to technical only, if you do not obtain in first 3 years.

Small suppliers and providers (whatever that means) potentially exempt from accreditation and can do external audit instead, and are also eligible for an additional 0.25% increase without risk of penalty.

Site neutrality finally. Exempt from the yearly whittling down of a few percent. Payments for transportation.

Seems like... Some good things?

I'm no fan of Astro and also all the carveouts make me give this the hard side eye, but I actually think this will dramatically help out practice. We bill MPFS freestanding rates and aggressively hypofractionate.

Tell me what I'm missing?

THe future and the second and third order effects of this whole thing are hard to predict.

I just operate from the heuristic that if the people writing/endorsing this are not actually participating in it, then I don't like it. It's simple, but as Walter Sobchak says, the beauty in this heuristic is in the simplicity.
 
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Large academic hospital systems should have lower costs than smaller community practices due to economies of scale. Even if they have higher costs, why should the government reward inefficiency with higher payments? The fact that they carved themselves out of the very bill they wrote is a textbook example of regulatory capture, and it is of course indefensible.
Isn’t there an anti-trust argument to be made here? Requiring accreditation and you’re one of the 3 groups providing accreditation? Policies that directly favor their centers preferentially (carve outs etc)? Didn’t someone post a link for reporting anti-trust to the government recently?
 
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ROCR sets conditions for a huge competitive advantage for large centers, pps and proton, to expand and bring more patients under their high cost umbrella. Ultimately, payments are very disconnected from CMS rates. Almost zero patients have pure medicare. Hospital negotiated prices are going up not down. If this was so great for our reimbursement, why would they exempt themselves.

They wouldn't. This is gaslighting. It's called a negative externality - someone making/proposing a change in which another party pays the cost of it. It is frankly wrong and I have much less respect for Michalski for this. Anyone supporting this should insist they be included. Include protons and include yourself.
 
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I have much less respect for Michalski for this. Anyone supporting this should insist they be included. Include protons and include yourself.
Try and mandate direct supervision for the entire profession but then exclude yourself from ROCR. Sounds about right. Dictator level stuff.
 
I'll read through this myself but:

In real life, when ASTRO met with my department, they were specifically asked "what changes have you made based on feedback". I did not ask the question.

The answer, from Adler, was something to the effect of "we removed the penalty for non-accreditation" (or something to that effect, I need to check my notes).

I'm reading this now, skimming, and this seems even worse...

It just flat out makes accreditation necessary but provides a nebulous exemption for "small radiation therapy provider" except...uh...ok I'll just screenshot it:

View attachment 386809

"A radiation therapy provider or radiation therapy supplier that is a small radiation therapy provider or small radiation therapy supplier may elect to satisfy the accreditation requirement..."

Is that English?

Am I going insane?

Does...I haven't slept much recently but that doesn't make sense as a sentence structure, does it?
Sounds like a conclusion sentence from a red journal fluff article.
 
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Not a huge fan of accreditation, but I think it won't be too onerous.

Agree some good things. Case based payments are ideal IMO. The reduction in duration of encounter to 30 days for bone and brain mets is prudent (and much better than 90 days).

In many cases, it's not clear to me that hypofractionation is actually helping the patient. The incentives are away from more protracted and often less toxic treatment in some circumstances. It is what it is.

The carve outs are the main thing however. They are not defensible and I have not heard a rational defense (just an argument from authority). The excess costs of care from PPS exempt places and proton places could have been assumed as judicious at present and factored into total cost models going forward. They chose to believe that they will achieve significant cost savings on the backs of community care while perpetuating low value care at name brand academic and proton centers. It totally sucks.

Accreditation is fairly onerous but that’s not the reason to dislike it. I like it as a voluntary program. The bad part is it is a free pass for three societies with overlapping engaged members to force practices to do anything they want or pay 1%.

PLUS every practice will also be sending lots of money to the societies, and the field gets nothing back for all that money. APEx and similar offers nothing at all to the field.

STS is less money, more impactful and they offer you a way to track outcomes and benchmark, and they use the data to drive quality improvement.
 
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Well folks, as expected, looks like the fix is in. You guys getting your chinese Mevion soon?
 
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Quality Adjustment: "ROCR Program for the technical component of such services shall be increased by 0.5 percent (or 0.25 percent in the case of such a provider or supplier that is a small radiation therapy supplier or small radiation therapy provider." So only affects technical component and is only 0.5% cut (or 0.25% for the nebulously defined small provider)? I agree getting accreditation is a waste of time/resources so I would just take the cut and nice that it (seemingly) doesn't affect the professional side. It does increase to 1% after 3 years, but again I would just personally take the cut and not accredit.

Frankly better than the time/effort/money it takes me to participate in MIPS and the bill does exclude rad onc from MIPS which is amazing (my practice is going to spend >1% of our Medicare revenues on a $3000 consultant/staff time/registry costs to meet MIPS requirements this year personally).

Exclusions: Looks like protons, brachy, etc are excluded. Section 3, subsection (j)(3)(B) "during the period beginning on the date on which the regulation issued pursuant to subsection (a)(1) become effective and ending on the date that is 10 years after such date, brachytherapy, proton beam radiation therapy services, intraoperative radiotherapy, superficial radiation therapy, hyperthermia, and therapeutic radiopharmaceuticals." Don't love the proton therapy exclusion, but I get that the proton lobby would kill this if included (practical reality). Brachy exclusion is bad for brachy monotherapy (but no worse than current FFS situation where brachy is way underpaid compared to EBRT) and good for combo treatment (since brachy would paid separate than the case rate for gyn/prostate etc)

Superficial RT exclusion: I actually prefer this as the average course of electrons for skin cancer pays less than the average course for SRT (even with IGRT) for Medicare. I assume SRT would go bananas in derm settings if they paid out $8k or whatever via the ROCR for 10-15 fraction SRT with IGRT (which is what some clinics do). So smart move by ASTRO to exclude SRT.

Overall as a small PP doc, I would support this bill and will be writing to my member of congress to that effect.
 
Superficial RT exclusion: I actually prefer this as the average course of electrons for skin cancer pays less than the average course for SRT (even with IGRT) for Medicare. I assume SRT would go bananas in derm settings if they paid out $8k or whatever via the ROCR for 10-15 fraction SRT with IGRT (which is what some clinics do). So smart move by ASTRO to exclude SRT.

Overall as a small PP doc, I would support this bill and will be writing to my member of congress to that effect.
The srt exclusion makes zero sense to me. It's a scam igrt wise and it isn't even good for patients when it's used inappropriately on larger tumors
 
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The srt exclusion makes zero sense to me. It's a scam igrt wise and it isn't even good for patients when it's used inappropriately on larger tumors
It’s about how the case rate is calculated, which is by looking at existing reimbursement. SRT would drive down the average case rate reimbursement for skin cancer, since on average SRT reimburses less than electrons nationally (if skin cancer is included in the model, I don’t know that it is).

So including SRT would hurt rad oncs and help derms. If anything, the derm lobby would push to include it
 
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It’s about how the case rate is calculated, which is by looking at existing reimbursement. SRT would drive down the average case rate reimbursement for skin cancer, since on average SRT reimburses less than electrons nationally (if skin cancer is included in the model, I don’t know that it is).

So including SRT would hurt rad oncs and help derms. If anything, the derm lobby would push to include it
With the bogus igrt ultrasound charges, it reimburses far more
 
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With the bogus igrt ultrasound charges, it reimburses far more
There is a company out there selling linacs for electrons to derms because of the better pro forma than SRT if treating >15-20 patients/month. Seriously. And there are derms in the southeast doing it.

SRT disallows a lot of normal rad Onc codes and average fractions for SRT that I’ve seen is 10-20 vs I typically do at least 20 (usually more) when treating skin cancer with electrons or IMRT for a more complicated patient with PNI etc. So I definitely get paid more, on average, than the typical SRT course (ultrasound can’t make up for the fact that SRT pays $40/fx plus can’t do normal rad Onc planning codes etc)
 
There is a company out there selling linacs for electrons to derms because of the better pro forma than SRT if treating >15-20 patients/month. Seriously. And there are derms in the southeast doing it.

SRT disallows a lot of normal rad Onc codes and average fractions for SRT that I’ve seen is 10-20 vs I typically do at least 20 (usually more) when treating skin cancer with electrons or IMRT for a more complicated patient with PNI etc. So I definitely get paid more, on average, than the typical SRT course (ultrasound can’t make up for the fact that SRT pays $40/fx plus can’t do normal rad Onc planning codes etc)
SRT as a practice expanding into the community through places like SkinCure is markedly increasing cost per case for skin cancer care.

I get referrals that were rejected by the local derm after IGRT was rejected (pretty much only medicare paying the bogus IGRT at this point). It's well worth their money to treat with the IGRT code, but it is not without it.

Most of the cases that they use the technique for are in fact cases that are appropriate for local excision. (Again, a marked increase in cost).

The cases where non-surgical management is a preferred first course (including nose, most face, poorly vascularized tissue abutting bone), electrons in the hands of a radonc is the way to go. (IMO less hypopigmentation and better dosimetry, particularly when factoring in underlying high density tissues).
 
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Quality Adjustment: "ROCR Program for the technical component of such services shall be increased by 0.5 percent (or 0.25 percent in the case of such a provider or supplier that is a small radiation therapy supplier or small radiation therapy provider." So only affects technical component and is only 0.5% cut (or 0.25% for the nebulously defined small provider)? I agree getting accreditation is a waste of time/resources so I would just take the cut and nice that it (seemingly) doesn't affect the professional side. It does increase to 1% after 3 years, but again I would just personally take the cut and not accredit.

Frankly better than the time/effort/money it takes me to participate in MIPS and the bill does exclude rad onc from MIPS which is amazing (my practice is going to spend >1% of our Medicare revenues on a $3000 consultant/staff time/registry costs to meet MIPS requirements this year personally).

Exclusions: Looks like protons, brachy, etc are excluded. Section 3, subsection (j)(3)(B) "during the period beginning on the date on which the regulation issued pursuant to subsection (a)(1) become effective and ending on the date that is 10 years after such date, brachytherapy, proton beam radiation therapy services, intraoperative radiotherapy, superficial radiation therapy, hyperthermia, and therapeutic radiopharmaceuticals." Don't love the proton therapy exclusion, but I get that the proton lobby would kill this if included (practical reality). Brachy exclusion is bad for brachy monotherapy (but no worse than current FFS situation where brachy is way underpaid compared to EBRT) and good for combo treatment (since brachy would paid separate than the case rate for gyn/prostate etc)

Superficial RT exclusion: I actually prefer this as the average course of electrons for skin cancer pays less than the average course for SRT (even with IGRT) for Medicare. I assume SRT would go bananas in derm settings if they paid out $8k or whatever via the ROCR for 10-15 fraction SRT with IGRT (which is what some clinics do). So smart move by ASTRO to exclude SRT.

Overall as a small PP doc, I would support this bill and will be writing to my member of congress to that effect.

You cannot be serious. A single skin CA exclusion is not worth this entire dumpster-fire of a bill meant to drive more cases to the higher cost centers and destroy private practices in the process.

This is just step 1. You will take a huge cut upfront and then cuts will continue from there as they always have. Rates won't go up. They never have and they never will. Including increases in this bill is just fantasy-land.

All technological advancements in this field will stop immediately. There will be no market for ANY new technology if you aren't paid more to implement them. It's just more cost that you will be eating. The demand for older sh** machines will increase so you can't even get those for cheap.

The excluded "academic" centers will continue to buy the newest machines since they can actually be paid more for their use and they will advertise to your patients about how much better their technology is than yours - and for once they will actually be right.

RTT and radonc job markets will be decimated. You don't need 2 radoncs for 10 on beam. You will still have to be there all day.

Protons exclusion is just dirty. They are a huge driver of cost with no proven benefit. If it won't pass without protons included, it shouldn't pass.
 
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