CMS Announces a Delay of Attestation and Reporting Requirement for the RO APM to January 1, 2022

In December 2020, the Centers for Medicare and Medicaid Services (CMS) announced changes to the RO APM, which is anticipated to begin on July 1, 2021, delaying attestation and reporting requirements until January 1, 2022. We are expecting updates and clarifications from CMS on these timelines.

The following attestation and reporting requirements are now due on January 1, 2022:

  • Individual Practitioner List (IPL). Sites can complete this list by visiting the Radiation Oncology Administrative portal

The following attestation is by January 30, 2022:

  • 2015 Edition CEHRT Attestation

The following attestation and reporting requirements are due to begin on January 1, 2022:

  • Collection of the 4 RO Model Clinical Quality Measures (CQMs) from January 1, 2022, through December 31, 2022 and submit in March 2023.
  • Collection of the Clinical Data Elements (CDEs). The first submission of the clinical data elements for January 1, 2022 through June 30, 2022 will be due in July 2022. CMS has not defined these elements at this time.

Due to the RO APM attestation and reporting delay until 2022, customers that were mandated to participate in MIPS and are now part of the RO APM must continue to participate in MIPS reporting for 2021.

What is the RO APM?

The RO APM is an advanced alternative payment model developed by the Centers for Medicare and Medicaid Services (CMS) in conjunction with the Center for Medicare and Medicaid Innovation. Under this model, Medicare will pay providers a predetermined, site-neutral, bundled rate for most radiation therapy services provided within a 90-day episode of care, rather than paying for each service individually. Participation in the model will be mandatory for select providers. The intended goal of the model is to incentivize providers to deliver radiation therapy services more efficiently while maintaining or improving the quality of care delivered.

Elekta is actively evaluating MOSAIQ Plaza, our suite of digital tools, to develop solutions that will support customers through the transition and implementation of the RO APM. CLICK HERE to request a demo and learn how MOSAIQ Plaza can help you today.


Education & Training

Elekta has provided and will continue to provide webinars and education regarding the RO APM as we learn more.

To view previous webinars visit:


A: The RO APM is an advanced alternative payment model developed by the Centers for Medicare and Medicaid Services (CMS) in conjunction with the Center for Medicare and Medicaid Innovation. On September 18, 2020, CMS released the RO APM final rule, which will go into effect on January 1, 2022.

Under this demonstration, Medicare will pay providers a predetermined, site-neutral bundled rate for most radiation therapy services provided within a 90-day episode of care, rather than paying for each service individually. The model is mandatory for providers in the zip codes selected to participate and is intended to incentivize providers to deliver radiation therapy services more efficiently while maintaining or improving the quality of care delivered.

A: The RO APM is several years in the making, starting in December 2015, when Congress passed the Patient Access and Medicare Protection Act (PAMPA), which required the Secretary of Health and Human Services to submit to Congress a report on “the development of an episodic alternative payment model” for radiation therapy (RT) services.

In November 2017, CMS released a report to Congress detailing options for an episodic model for RT services. In July 2019, CMS released a proposed rule detailing the specification for the model, which was open for public comment for 90 days. Elekta, along with over 300 other providers, patient groups, industry groups, and physician specialty societies, submitted comments supporting or disagreeing with various aspects of the model and recommending changes that should be made in the final rule.

CMS released the final rule in September 2020, and the RO Model is scheduled to be implemented on July 1, 2021. A few of the changes requested by stakeholders were incorporated, while others were not. It is important to note that there are several areas of outstanding advocacy associated with the model including payment for treating multiple disease sites or using multiple treatment modalities in a single episode of care.

A: All major technologies used to deliver radiation therapy episode are included in the RO APM per the final rule. This includes external beam (3D, IMRT, SRS, SBRT, IGRT), brachytherapy, and proton beam therapy. The final rule includes an exemption for patients undergoing proton beam therapy that enrolled in a federally funded randomized control trial. The final rule excluded Intraoperative Radiation Therapy (IORT) and radiopharmaceuticals.

A: Participation in the RO APM is determined by the zip code of the radiation therapy provider. CMS selected core based statistical area (CBSA) which draws geographically similar areas by zip code. Thirty percent of all episodes of care for RT in the model and hopes to geographically match CBSAs both in and outside the model. All providers, hospitals, and freestanding centers furnishing RT services within a given CBSA are required to participate.

A: Sites in Maryland and Vermont, prospective payment system exempt cancer hospitals, ambulatory surgical centers, and critical access hospitals and those with the Pennsylvania Rural Health designation are exempt from participating in the model. Additionally, the RO APM only applies Medicare fee for service patients receiving services from RO APM participants. Patients with Medicare Advantage, Medicaid, or commercial insurance will not paid under this model.

A: The final RO Model includes a "low volume opt-out" for any participating physician group practice, freestanding radiation therapy center, or HOPD that provided fewer than 20 episodes in the most recent year with claims data available.

A: Payment under the RO APM will be assigned based on the diagnosis of the patient instead of the technology used to deliver care, meaning that payment will be technology agnostic. There are 16 cancer types covered by the RO APM which will be assigned via ICD 10 codes. These sites are inclusive of all standard cancer disease sites except for skin. RT services furnished for the treatment of diseases outside of these disease sites, including skin cancer, are excluded from the RO APM and will be paid under traditional Medicare FFS.

The disease sites are:

Anal Cancer CNS Tumors Pancreatic Cancer
Bladder Cancer Colorectal Cancer Prostate Cancer
Bone Metastases Head and Neck Cancer Upper GI Cancer
Brain Metastases Liver Cancer Uterine Cancer
Breast Cancer Lung Cancer  
Cervical Cancer Lymphoma  

A: CMS calculated national base rates for the technical and professional component for each of the 16 cancer types under the model using historical hospital outpatient billing data from 2016 to 2018. Payment under the RO APM will be site neutral, meaning that payments in the freestanding radiation therapy centers will be calculated using the same methodology as payment for hospital outpatient departments.

A: Under the RO APM, participants will receive a single bundled payment for almost every radiation oncology service provided in a 90-day episode of care. A treatment planning code will trigger the start of the 90-day episode. Participants will receive 50 percent of the bundled payment at the start of the episode and 50 percent of the bundled payment at the end of the episode, or at the end of treatment. The 90-day episode will be followed by a 28-day clean period in which any services delivered will be paid fee for service (FFS). After the 28-day clean period, a new bundle can be triggered.

A: Both providers and hospitals in selected zip codes are required to participate. There will be three types of participants in the RO APM:

  • Professional: Individual physicians or physician groups billing under PFS that furnish just the professional component (physician-dependent services) at a freestanding center or hospital outpatient department
  • Technical: Hospital outpatient departments or freestanding centers that furnish only the technical component (equipment, overhead, etc.) of radiation therapy; and
  • Dual: Dual participants are typically in the freestanding setting and may be used when the providers performing radiation also own the location where it is delivered, meaning they furnish both the technical and professional components.

A: The RO APM payment methodology is site-neutral, meaning payment is established using a common methodology, regardless of the setting of care where it is furnished. This means that the base rates, which service for both the freestanding and hospital outpatient setting will be the same and the payment methodology is not dependent on the site of service.

A: The RO Model is an Advanced APM and a MIPS APM under QPP. RO APM participants need to annually certify their intent to the use of Certified Electronic Health Record Technology (CEHRT), include quality measure performance as a factor when determining payments, and bear more than a nominal amount of financial risk. RO Model participants who are APM Entities and eligible clinicians seeking Qualifying APM Participant (QP) status in an Advanced APM must comply with all RO Model requirements in order to be eligible for Advanced APM incentive payments. Participants who do not meet the QP threshold would not qualify for the Advanced APM incentive payment and instead would be in a MIPS APM.

A: MOSAIQ can be used to report on and submit on the four quality measures required under the RO APM. Customers can reach out to Elekta support @1-855-My-Elekta to obtain the RO_MODEL 2021 assessment for reporting.

A: Elekta is wholly engaged in understanding the requirements of the RO APM and is in the process of updating our MOSAIQ software to allow for reporting and submission of the four quality measures and data submission requirements for the RO APM. In addition, Elekta is making enhancements to other solutions to better allow for our customers to track, submit, and optimize workflows to better accept a bundled payment arrangement.

Additional Resources


Responsibility for compliance with the Radiation Oncology Alternative Payment Model’s (RO APM) regulations and guidelines rests entirely with the eligible professional or delegate.

Elekta makes no representation of expertise in the Radiation Oncology Alternative Payment Model (RO APM). Elekta advises each eligible professional or delegate to seek its own counsel or advisors in determining how best to interpret, apply, and comply with the Radiation Oncology Payment Model (RO APM) objectives.

Any training and documentation provided by Elekta are for informational and reference purposes only. Elekta makes no representation, warranty, or guarantee of completeness, accuracy, applicability, or validity of the training and documentation provided. Elekta disclaims liability for any loss or claimed damages that may arise from reliance on or use of information contained in any training and documentation provided by Elekta.

Elekta makes no representation, warranty, or guarantee that an end user of the MOSAIQ® oncology information system will meet the requirements for RO APM or demonstrate adequate compliance with the Radiation Oncology Alternative Payment Model (RO APM).