March 1, 2021
Elizabeth Richter
Acting Administrator, Centers for Medicare and Medicaid Services
The U.S. Department of Health and Human Services
Hubert H. Humphrey Building
200 Independence Avenue, S.W.
Washington, D.C. 20201
Dear Ms. Richter:
On behalf of the radiation oncology stakeholder community, including radiation oncologists, members of the radiation oncology cancer care team, group practices, hospitals, patient advocates, device manufacturers and more, we are writing to share our collective concerns about the Radiation Oncology (RO) Model, as it is currently designed, in the hopes of working with the new Administration to achieve our shared goals of value-based radiation oncology care. Ultimately, we believe that the RO Model is overly focused on achieving significant savings, at the risk of hurting access to care and quality. We understand that the Centers for Medicare and Medicaid Innovation (CMMI) is developing a proposed rule, and we want to ensure that our common concerns are fully understood and considered for incorporation into the RO Model proposed rule. We appreciate President Biden’s longstanding leadership in the fight against cancer, and we believe the RO Model, with reforms, represents a real opportunity to advance radiation therapy care for cancer patients. The community remains committed to a RO Model that balances the needs and goals of Medicare and radiation oncology, while ensuring patient access to high value cancer care.