Clean Period

A standard RO Model episode is a maximum of 90 days.  That is 89 days after the initial treatment planning service date.  At that time the “Clean Period” starts.  The Clean Period lasts for 28 days.  That means it can last until 118 days after the episode.

Why is it called the Clean Period?

The idea of the clean period is based upon common treatment guidelines.  Generally, a missed week of treatment is a normal occurrence.  However, a gap of treatment for four weeks or 28 days would be an indicator that the previous treatment course and episode has completed.  In most circumstances, services rendered after this period would be considered to be part of a new episode or treatment course.  Hence, 28 days is a symbolic time frame meant to buffer the current episode from a new episode.  If the patient is to receive a new episode, then you can see the clean period as a bridge between episodes.

Services rendered inside the Clean Period

During the Clean Period, if further radiation therapy services are deemed clinically appropriate, then these services are to be billed differently than during the standard episode period.  While in the Clean Period, the services rendered by the RO Model participant to the episode patient should be billed in the traditional fee-for-service methodology.  The bundled M-Code billing is put aside during this period.  You will bill the traditional fee-for-service CPT codes just as if you were not an RO Model Participant.

Appropriate and Medically Necessary Services Only

While the Clean Period allows for fee-for-service billing, it is not intended to be a free for all.  CMS has very clearly indicated that they will monitor the use of the clean period as well as any follow up services for a single beneficiary.  The clean period is meant to be a symbolic period that represents the end of a standard treatment episode where extra services are only billed when necessary.  By all intents and purposes, this period is expected to be a gap period that represents the end of treatment for a beneficiary or a break before a new episode begins.