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cms proton beam therapy

As noted by the AHA, “the hospitals and health systems that would be required to participate in [the RO Model] are of many different sizes and types and are at different points in the process of transitioning to value-based care. People who would like to be considered for proton beam therapy at Mayo Clinic must schedule an appointment for a radiation oncology consultation. As a result, oncologists and their patients may soon find themselves with fewer (and possibly less effective) RT alternatives to choose from. Today, many pediatric cancers have significant cure rates — some higher than 90 percent. Proton beam therapy is an advanced type of external-beam radiation therapy that uses proton rather than photon beams to deliver radiation doses to a tumor. exponentially the farther it travels. Overall, the Alliance is concerned that CMS’s large cost-saving goal and scope of this RO Model puts patients at risk. John M. Tilton is an associate in the Healthcare Practice Group in the firm’s Century City office. In order to address these concerns the AHA Letter calls for the following revisions to RO Model: In addition to the foregoing, the AHA, like the COA, is concerned that by making the RT Model mandatory for those RT providers located in the selected geographic area creates an unfair and unnecessary burden on the providers who have no choice but to participate in the RT Model program. … In general, proton beam radiotherapy is not indicated for cancers that are widely disseminated, such as leukemias or malignancies with hematogenous metastases or as a short term palliative procedure. Founded in 1990, the NAPT … On July 10 2019, the Centers for Medicare & Medicaid Services (“CMS”) issued a Notice of Proposed Rulemaking (“NPR”) entitled, “Medicare Program; Specialty Care Models to Improve Quality of Care and Reduce Expenditures.” In the NPR, CMS proposes to implement two new mandatory specialty care payment models – one of which, the Radiation Oncology Model (“RO Model”), applies to selected radiation therapy (“RT”) services[1] as provided by physician group practices, hospital outpatient departments, and freestanding radiation therapy centers, all located within randomly selected geographic areas throughout the country. As described in the NPR, the RO Model creates a quality-based payment system that is intended to, “reduce Medicare, Medicaid, and Children’s Health Insurance Program (CHIP) expenditures while preserving or enhancing the quality of [radiation therapy services] to the beneficiaries of such programs.” The RO Model links RT payments to quality through the assessment of RT provider-reported quality data against traditional quality metrics including patient satisfaction thresholds. Mayo Clinic doctors and other specialists will review your case and consult with you to discuss all treatment options. In addition to the above concerns, some stakeholders have objected to the reimbursement reductions that are part and parcel to the RO Model as creating a possible chilling effect on RT-related innovation and the development and use of new RT technology. Proton beam therapy will be the best option for certain patients and tumor types, while others may benefit from a different approach — another type of radiation therapy or no radiation at all. The RT community will be watching and so will we. APTA suggests three changes in its comment letter that would minimize the negative impact: (i) make the RO Model voluntary; (ii) encourage more evidence-gathering on proton therapy by expanding the exclusion parameters to include proton patients enrolled in all clinical trials and data registries; and (iii) create a more appropriate base rate for reimbursement that won’t disincentivize providers from recommending proton therapy when it’s the best treatment option. The National Association for Proton Therapy (NAPT) is a non-profit organization founded to educate and increase public awareness about the clinical benefits of proton beam therapy. "Mayo," "Mayo Clinic," "MayoClinic.org," "Mayo Clinic Healthy Living," and the triple-shield Mayo Clinic logo are trademarks of Mayo Foundation for Medical Education and Research. In order to accommodate the treatment of patient populations with varying acuity levels with a variety of RT modalities, the COA recommends that the national base amount calculation be adjusted to reflect the costs of treating both higher and lower acuity oncology patients with a variety of RT modalities. For therapy at a freestanding facility, you pay 20% of the Medicare-approved amount for the therapy, and the Part B deductible applies. Proton beam radiation therapy (PBRT) is intended to deliver higher, more targeted radiation with less damage to collateral healthy tissue than external beam radiation therapy (EBRT) using photons (x … For most tumor sites, a standard course of treatment is five to seven weeks, with treatments delivered five days per week. Proton therapy is a form of external beam therapy for which powerful equipment is used to generate beams that penetrate the body. This content does not have an English version. A letter from your local provider summarizing your medical condition, A complete record of your immunizations to date, Copies of medical record information from health care providers outside of Mayo Clinic, Radiologic films, CDs, DVDs, videos and written radiologic reports related to the clinical question, Pathology slides and written pathology reports from relevant biopsies. Together, you will develop a treatment course that best fits your needs and condition, whether that treatment is proton beam therapy or another option. As described below, some of the fears expressed by AHA, COA and their constituents relate to the payment adjustment factors that are not included in the RO Model payment calculation methodology. integral dose (dose to the whole body of the patient) compared to conventional x-ray therapy. This alert is provided for information purposes only and does not constitute legal advice and is not intended to form an attorney client relationship. Proton therapy treats cancer using protons instead of X-rays employed by traditional radiation therapy. A single copy of these materials may be reprinted for noncommercial personal use only. - Proton treatment delivery to one or more treatment areas utilizing two or more ports per treatment area with matching or patching fields and/or multiple isocenters, with custom blocks and compensators. People who must undergo radiation therapy early in life are less likely to have long-term side effects and complications, such as secondary cancers, with proton beam therapy than with conventional radiation therapy. On September 16, 2019, the Alliance for Proton Therapy Access (the “APTA”) submitted to CMS its comment letter to the NPR and CMS’s inclusion of proton beam therapy in the five-year RO Model implementation plan. Proton beam therapy (PBT) is a U.S. FDA approved technology that delivers external beam radiation with positively charged atomic particles to tumors. Mayo Clinic wants to help make your travel to Mayo Clinic as easy as possible. On November 3, 2017, the Center for Medicare and Medicaid Innovation (“CMS Innovation Center”), a component within the Center for Medicare and Medicaid Services (“CMS”), complied with PAMPA and released Report to Congress: Episodic Alternative Payment Model for Radiation Therapy Services (the “Report”). As for those adjustment factors that are not included in the RO Model payment calculation, the adjustment factors do not include adjustments based upon the type of RT provider (the site-neutrality component) or the type of RT modality at issue. In its comment letter, APTA writes that if the RO Model will not exclude proton beam therapy completely, CMS should minimize the negative impact that the RO Model would have on cancer patients who benefit from proton therapy. (CPT 77524) 3. [1] The selected RT services are EBRT (External Beam Radiation Therapy), IMRT (Intensity-Modulated Radiation Therapy), SRS (Stereotactic Radiosurgery), SBRT (Stereotactic Body Radiation Therapy), Proton Beam Therapy, IORT (Intraoperative Radiation Therapy), IGRT (Image-Guided Radiation Therapy), and Brachytherapy. Some companies do not reimburse for the service or only cover treatment for certain … Mayo Clinic specialists will work with you to develop the most effective treatment options tailored to your individual situation. This means highly specialized radiation oncologists work in a multidisciplinary environment that considers all your needs. Intraoperative Radiation Therapy (IORT) 77424: Intraoperative radiation treatment delivery, x-ray, single treatment session Yes: 77425 Intraoperative radiation treatment delivery, electrons, single treatment session Yes Proton Beam Radiation Therapy 77520 Proton … Proton beam therapy … As summarized by CMS, the Report identified three reasons why, “radiation therapy is ready for payment and service delivery reform: the lack of site neutrality for payments; incentives that encourage volume of services over the value of services; and coding and payment challenges.”. We believe that Medicare patients should be able to receive the best treatment that is recommended by their oncologists, and this rule may prevent thousands of Medicare beneficiaries from doing so. The RO Model is one such alternative payment model. That means that there is no national rule, so the decision is … CMS's Coverage Issues Manual can be found on the CMS website. The length of … This treatment option is painless for the … It’s essential that you and your primary oncologist submit a request for coverage of your proton therapy … A prime example of the potential negative impact that the RO Model may have on the proliferation of innovation in the RT arena can be best understood through the reaction of proton beam therapy providers and professional associations to the RO Model. Proton beam radiotherapy is a form of external beam radiation that offers better precision … This includes any appeals process with the insurance company. Travel specialists provide information and a variety of services to help. This experience means your doctors are equipped with the knowledge and resources to provide you with exactly the care you need. As proposed, the RO Model is a prospective payment system that reimburses RT providers for RT treatment planning, technical preparation and special services, RT delivery, and RT management on a bundled basis (including both the technical and professional components of the RT services) for a 90-day episode of care. New Technology and RT Therapy. Cancer patients deserve the right to work directly with their doctors to make the best choices about their treatment options – choices that improve their chances of survival and preserve their quality of life. At Mayo Clinic, your radiation oncologist will have a full range of treatment options and provide guidance for optimal care. The absence of such adjustment factors are important in that they explain, in some part, the concerns of those in the RT provider community who take issue with the RO Model. Pediatric tumors are among the most beneficial to treat with proton beam therapy, as it imparts less damage to a child's still-developing organs. With proton therapy, the energy beams stop after reaching their target. The Final Rule is anticipated to be published mid to late November. Proton beam therapy is targeted and helps to spare healthy tissue from the effects of radiation. This content does not have an Arabic version. This may include but is not limited to: Please let us know if you have any metal hardware in your body, including pacemakers and hip replacements. Shortly after my treatment, I was asked to provide my story to The Alliance for Proton Beam Therapy Access Association. Coverage is determined on a case by case basis depending on your diagnosis, medical history and other factors. Finally, RO Model payments do not differentiate between the type of RT provider, the RT modality, or the RT modality’s cost. You do not need a referral from a doctor. Also Known As: Proton beam radiation therapy, Proton radiotherapy PRIOR AUTHORIZATION: Required. At Mayo Clinic, the needs of the patient come first. The physician work is billed under treatment planning and treatment … Due to its unique radiation … The denial document said there was no evidence that Mr. Hoppe, 67, would get any added advantage from proton-beam therapy, which is significantly more expensive than conventional X-ray radiation. In this doc (dated 27 Nov 2012) it cites "Proton beam therapy for prostate cancer" as "No NCD, local coverage policies in place". Proton beam therapy … People who must undergo radiation therapy early in life are less likely to have long-term side effects and complications, such as secondary cancers, with proton beam therapy than with conventional radiation therapy. Coverage varies by insurance company and disease type. Use the Search by Document ID feature if you know the ID of the document you are looking for (e.g., A12345, L12345, CAG-12345, 123.45). Make the model retrospective rather than prospective, to allow CMS to reconcile providers’ historical and actual case mix and avoid under or over payments; Replace the RO Model’s historical experience and efficiency adjustments with an adjustment that blends participants’ historical performance and national and regional average performance, as has been done in other models; Lower the discount amount, especially for the technical component (TC) payment, to 2.5% – 2.75%; Incorporate a stop-loss provision into the RO Model; Develop approaches to ensure that appropriate payments are made when providers introduce new service lines or technologies that were not included in their historical data; and. Proton Beam Therapy. This site complies with the HONcode standard for trustworthy health information: verify here. Medicare generally covers proton beam therapy. Dhara Waghela is an associate in the Corporate Practice Group in the firm’s Century City office and is a member of the firm’s Healthcare team. As one example of how these “three reasons” are reflected in the RO Model, the Report and in the NPR, the RO Model’s episodic payments are calculated based upon CMS-proposed national base rates, trend factors, and adjustment factors applied to each participating RT provider. Section 3(b) of the Patient Access and Medicare Protection Act (“PAMPA”) (P.L. Each year, almost 120,000 people with cancer receive care at Mayo Clinic. Coronavirus Aid, Relief, And Economic Security Act Of 2020: Telehealth Front and Center, INFORMATION BLOCKING AND THE RIGHT TO ACCESS INITIATIVE: Why Patients Struggle to Obtain their Medical Records and what the Office of Civil Rights Intends to Do About It, CMS and OIG Propose Regulatory Changes Impacting the Scope of the Stark Law and the Federal Health Care Program Anti-Kickback Statute, Bipartisan Push To Repeal ACA’s Cadillac Tax, Proposed and Expanded Disclosure Obligations for Hospitals Regarding not Only Gross Charges, but Third Party Payor Pricing as Well, June 2018 Report to the Congress: Medicare and the Health Care Delivery System, Patient Access and Medicare Protection Act, Report to Congress: Episodic Alternative Payment Model for Radiation Therapy Services, New Telehealth Series: The “State” of Telehealth, Day 3 Notes for the 39th Annual J.P. Morgan Healthcare Conference, 2021, Day 2 Notes for the 39th Annual J.P. Morgan Healthcare Conference, 2021, Day 1 Notes for the 39th Annual J.P. Morgan Healthcare Conference, 2021, Government Contracts & Investigations Blog, New York Commercial Division Round-Up Blog, Real Estate, Land Use & Environmental Law Blog, U.S. Legal Insights for Korean Businesses, The COA objects to the RO Model as a mandatory demonstration project that, “fundamentally and effectively [changes] Medicare reimbursement policies” for those RT providers located in the CMS-selected geographies where the RO Model is to be tested. According to the APTA. *CMS is considering excluding Proton Beam Therapy from the bundle when the beneficiary is participating in a federally-funded, multi-institution randomized controlled clinical trial FFS: Fee for Service; HDR: High Dose Rate; IGRT: Image Guided Radiation Therapy; IORT: Intraoperative Radiation Therapy… Your treatment plans take your values and preferences into account. Proton therapy offers a high … Note To find out how much your test, item, or service will cost, talk to … In this article, we will focus on the concerns of such detractors, including those voiced by proton therapy providers who consider the RO Model’s payment reductions – which apply to all RT providers regardless of the treatment modality at issue – as a CMS-intended financial hit against proton beam therapy. Such adjustment factors include each RT provider’s case-mix, historical experience, and geographic location. Mayo Clinic doctors and other specialists consult with their colleagues about each patient's condition and recommend treatment options based on their experience and evidence-based medicine. The APTA’s comment letter sums up many of the RO Model concerns that seem to be commonly accepted within the proton beam therapy provider and trade association communities. Tumors near the brain also can highly benefit from proton beam therapy because there is no exit radiation to cause additional tissue damage. Finally, the NPR includes CMS’s request for public comment regarding the inclusion of proton beam therapy in the RO Model. In this article, we will focus on the concerns of such detractors, including those voiced by proton therapy providers who consider the RO Model’s payment reductions – which apply to all RT providers regardless of the treatment modality at issue – as a CMS-intended financial hit against proton beam therapy. All rights reserved. Your doctors will take the time to get to know you and understand your treatment goals. In contrast, conventional external beam radiation therapy (EBRT) delivers radiation to all involved tissue, diseased and normal, and targeted tissue receives 60–70% of the intended dose. Proton therapy involves directing a beam of radiation from a machine placed outside of the body and delivering it through the skin and into the cancerous tissue. Learn about proton beam therapy, including possible side effects, pretreatment planning, treatment sessions and follow-up care, and how specialists determine whether treatment is affecting your cancer. Proton beam therapy is typically performed on an outpatient basis. Sheppard Mullin’s Healthcare Law Blog is designed to provide breaking industry news, legal analysis, and updates on emerging issues involving a variety of related topics. In the NPR, CMS calls out proton beam therapy as an expensive RT treatment modality that may be adversely and significantly impacted by the RO Model. The benefits of pencil beam proton therapy include: Ability to deliver higher therapeutic doses of radiation to tumors More accurate targeting of tumors Lower radiation exposure to normal … For example, in the NPR, CMS notes that The Institute for Clinical and Economic Review (“ICER”), after evaluating the evidence of the overall net health benefit (which takes into account clinical effectiveness and potential harms) of proton beam therapy in comparison with other RT treatment alternatives, concluded that, “[proton beam therapy] has superior net health benefit for ocular tumors and incremental net health benefit for adult brain and spinal tumors and pediatric cancers.” In addition, CMS notes that, “ICER judged that proton beam therapy is comparable with alternative treatments for prostate, lung, and liver cancer, although the strength of evidence was low for these conditions.”. CMS invites comment on its proposal to include proton beam therapy in the RO Model. The AHA believes that the RO Model as described in the NPR would place too much risk and burden on providers with little opportunity for shared savings as a reward. The Agency sites reports from Institute for Clinical and Economic Review (ICER) and the Medicare Patient Advisory Commission (MedPAC) in which both groups purport that proton beam therapy is of lower value when compared with other forms of radiation therapy. In our opinion, the proposed rule will take away those choices from far too many patients, leading to potentially devastating consequences including unnecessary suffering and, in some cases, death. But proton therapy is relatively new and costly for providers to administer. Specifically: As noted by the AHA in its September 16, 2019 comment letter, although the AHA and its member organizations share a mutual desire with CMS to move towards a more accountable and streamlined system of care, the AHA’s RO Model concerns arise from a difference of opinion regarding how to best pursue this shared goal. CMS has yet to issue a national coverage rule for proton beam therapy or its specific indications. Make a donation. 114-115) requires the Secretary of Health and Human Services to submit a report to Congress on the development of an episodic alternative payment model for the provision of radiation therapy services furnished in non-facility settings. In short, episodic alternative payment models (also called “bundled payment models”) are alternative payment methods in which the payer sets a single spending target for all applicable health care services furnished during a clinical episode of care over a specified period. POLICY: SWHP may consider proton beam radiation therapy … Any use of this site constitutes your agreement to the Terms and Conditions and Privacy Policy linked below. Please contact your Sheppard Mullin attorney contact for additional information. Our patient appointment coordinator will provide you with a list of medical records needed in advance of your appointment. Mayo Clinic’s radiation oncology programs, including proton beam therapy, have patient experience coordinators to help you manage your stay. In contrast, the energy of a proton beam is released at the end of its path, a region called the Bragg peak. The proton beams accelerated, bent and focussed in the FCC-hh will reach a centre of mass energy up to 100 TeV. REPORTING PROTON BEAM THERAPY ICRU 78 RAJESH THIYAGARAJAN Senior Medical Physicist & RSO MedantaThe Medicity. Ken is a partner in the Corporate Practice Group in the firm’s Los Angeles office and a member of the Healthcare Team. We fear this aggressive approach will be disruptive to providers who are likely to no longer offer these life-saving services because the reimbursement rates you are proposing will not come close to covering the cost of PBT, thereby preventing Medicare beneficiaries from accessing this medically proven method of treating certain types of cancer. HISTORY OF PROTON THERAPY • Robert Wilson proposed the use of proton in ... zrefin water, in a proton beam … © 1998-2021 Mayo Foundation for Medical Education and Research (MFMER). During circulation each beam will emit synchrotron radiation and generate an image current, causing a heat transfer of about 31.4 W/m to each beam … In response to the ICER conclusions, as well as the MediPac Report conclusions referenced above, CMS wrote in the NPR that, “[g]iven the continued debate around the benefits of [proton beam therapy], and understanding that [proton beam therapy] is more costly, we believe that it would be appropriate to include [proton beam therapy] in the RO Model’s test, which is designed to evaluate, in part, site neutral payments for RT services.” Notwithstanding the foregoing, CMS noted in the NPR that proton beam therapy, if provided to patients who are enrolled in federally-funded, multi-organizational, randomized control clinical trials, may be excluded from the RO Model’s reach. Although the proposed RO Model is consistent with broader trends in the healthcare industry to cut healthcare costs and increase quality through the use of bundled and other alternative (i.e., not fee-for-service) payment methodologies, the RO Model has garnered its fair share of detractors within the RT community. The COA maintains that the RO Model should be voluntary because, “not all RT providers have the infrastructure, commitment, and organizational buy-in to succeed in new payment arrangements.” Moreover, the COA notes that if RT providers are required to participate, they may not have adequate support to achieve the RO Model’s goals – the provision of high quality RT services at lower rates – while ensuring that they continue to meet the needs of their patients; and. Geographic location patient travel services needed in advance of your proton therapy Basics our patient appointment coordinator provide! 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