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CMS Discusses Potential Oncology Payment Model, Solicits Feedback Through Informal RFI

November 05, 2019

McDermott+Consulting

The Centers for Medicare and Medicaid Services (CMS) Center for Medicare and Medicaid Innovation (Innovation Center) held a public listening session on Monday, November 4, 2019, to discuss a new oncology payment model that builds on the current Oncology Care Model (OCM). CMS is calling this new model the Oncology Care First Model (OCF). The OCM is scheduled to end on June 30, 2021. CMS is proposing the OCF as a voluntary, five-year, multi-payer model that would run from January 2021 to December 2025.

As currently proposed the OCF would include both physician group practices and hospital outpatient departments that provide oncology care. The model would hold participants accountable for the total cost of care (including drug costs and adjusted for quality and cost relative to the benchmark and target amounts) and they would receive a performance-based payment (e.g. two-sided risk). Participants would also receive a steady stream of revenue through a monthly population payment. The Innovation Center is accepting feedback on an informal request for information (RFI) on this potential new model until November 25, 2019. Written comments can be sent to OCF@cms.hhs.gov.

At the public listening session, CMS solicited feedback on how to best improve the quality of care for cancer patients, potential payment methodologies, and risk arrangements. In her opening remarks, CMS Administrator Seem Verma reiterated the agency’s commitment to value-based care and reminded the audience that it was a bi-partisan priority that pre-dates the Trump Administration. She indicated that currently the Innovation Center is focused on implementing more models and working on meeting goals such as the release of real-time data to help model participants better understand their performance in a timely manner, improvements to interoperability to enhance care coordination, and the reduction of the administrative burden of participating in these models to allow providers to focus on patient care.

During the public listening session stakeholders provided a range of feedback to CMS. Highlights of the comments are below.

  • There was general support for the proposal to continue the OCM quality measures in the OCF.
  • There was some concern expressed that all practices, especially smaller and rural practices, would be able to implement the proposed electronic patient-reported outcomes.
  • Multiple commenters asked CMS to consider the amount of data that is currently collected in OCM and if there were ways to reduce what will be collected for the OCF model.
  • The enhanced use of national guidelines as well as clinical pathways was suggested.
  • Better coordination and engagement with IT vendors; currently for the OCM practices are not able to get their EHRs to extract the necessary quality and other data and end up extracting the data manually.
  • Multiple commenters recommended that CMS not automatically require current OCM participants to take on two-sided risk and to allow for one year of one-sided risk.
  • If total cost of care was to be considered, commenters indicated that CMS needed to include more detailed clinical data, should only consider the cost of the oncology care, and have a broader discussion on if the episode should begin at the time of diagnosis.

More information about the model can be found on the CMS OCF website.

 

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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 or Mara McDermott at 202-204-1462/mmcdermott@mcdermottplus.com.

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