CMMI Provides Further Details on OCM COVID-19 Flexibilities

On Friday, June 5, 2020, the Centers for Medicare and Medicaid Innovation (CMMI) hosted a conference call to review the COVID-19 flexibilities announced for the Oncology Care Model (OCM). Under the OCM, physician practices have entered into payment arrangements that include financial and performance accountability for episodes of care surrounding chemotherapy administration to cancer patients.

COVID-19 Flexibilities

In light of the impact the pandemic is having Medicare oncology providers, CMMI announced a series of flexibilities for the model. The agency indicated that in developing these flexibilities they considered a number of factors such as: using flexibilities that exist in the current model design, maintaining sufficient financial incentives, ensuring quality and consistency across CMMI models, minimizing risk for providers and CMS, minimizing delays in implementation of a new model, minimizing reporting burden, aligning with other national value-based and quality programs, and complementing other COVID-19 flexibilities previously implemented by the agency.

CMMI is implementing the following flexibilities for OCM practices:

  • Payment Methodology
    • Option for OCM practices to elect to forgo upside and downside risk for performance periods affected by the public health emergency (PHE)
    • For OCM practices that remain in one- or two-sided risk for the performance periods affected by the PHE, remove COVID-19 episodes from reconciliation for those performance periods
  • Quality Reporting
    • Make the following optional for the affected performance periods:
      • Aggregate-level reporting of quality measures
      • Beneficiary-level reporting of clinical and staging data
    • Remove the requirement for cost and resource utilization reporting and practice transformation plan reporting in July/August 2020
  • Timeline
    • Extend model for 1 year through June 2022

On the call, CMMI responded to many questions and provided clarifications on the flexibilities.

  • The current model is made up of nine performance periods. CMMI confirmed that the payment methodology flexibilities would apply to the 7th and 8th performance periods (episodes beginning 7/2/19 to 7/1/20) and they anticipate that it would extend to the 9th performance period which begins on July 1, 2020. The extension of the model through June 2022 would create a 10th and 11th performance period. They do not anticipate that the flexibilities would extend to these final performance periods.
  • CMMI is working on an option where practices can select different flexibilities for different performance periods.
  • While practices can choose to forgo upside or downside risk, practices are not able to change their risk arrangements (e.g. a practice participating in the OCM two-sided risk arrangement cannot switch over to the OCM one-sided risk arrangement).
  • Practices that participate in the extension period will need to sign a formal agreement.
  • Assuming practices continue to provide enhanced services, CMMI will continue to pay the Monthly Enhanced Oncology Services (MEOS) payment.
  • For a COVID-19 case to be removed, there must be a diagnosis of a confirmed COVID case on the Part A or B claim.
  • The implementation timeline for the future Oncology Care First (OCF) Model, the proposed successor to the OCM, will be adjusted due to the extension of the OCM model. The five-year OCF model was scheduled to begin on January 1, 2021. CMMI did not have a date for when applications would be available or when the new model will begin. CMMI has indicated that they will be considering lessons learned during the PHE as they finalize details of the model.

 

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For more information visit the McDermottPlus Payment Innovation Resource Center or contact Sheila Madhani at 202-204-1459/smadhani@mcdermottplus.com.