On November 1, CMS released an informal Request for Information (RFI) for their proposed Oncology Care First model. This proposed model is designed to be a successor to the Oncology Care Model (OCM), which is ending in 2021.
As the comment period closes on December 13, we don’t know exactly what the final version of the OCF will be, but we expect to see the final model announced in the first half of 2020. Practices will need plenty of time to get ready for the OCF start date, and we plan to dive into the final model once it is released.
What is the OCF model
Similar to the OCM, the OCF is proposed as a 5-year model. OCM is currently scheduled to end in June 2021 (six-month episodes would initiate no later than December 31, 2020, and therefore end no later than June 30, 2021). The OCF has proposed a start in January 2021, when no new episodes would be initiating in OCM at this time.
The goals of OCF align with the goals of OCM, with the plan to test the use of innovative, value-based cancer care to reduce total cost of care while improving care quality for patients. CMS stated that they built the OCF with the learnings from the OCM in mind. It is a multi-payer
model that isand designed to encourage more comprehensive oncology practice transformation and also has the potential to translate the improvements for non-Medicare fee-for-service patients.
Beneficiaries and payment under OCF
OCF has two proposed payment structures: the monthly population payment (MPP) and the performance-based payment (PBP). The MPP includes a wider scope of patients as beneficiaries and qualify for payment, compared to the OCM. In the OCM, practices receive Monthly Enhanced Oncology Services (MEOS) payments for beneficiaries who receive chemotherapy, but under the MPP payment is possible for beneficiaries on chemotherapy, on hormonal therapy only, or even those not receiving cancer-related drugs but are undergoing care from their oncologist. In the RFI listening session that CMS hosted, one attendee stated that approximately 40% of the cost of cancer care happens before chemotherapy is initiated, which is why it’s essential to capture more of the cancer patient population in these models.
Of course, the Performance Based Payment episodes (PBP), are still focused on initiation of chemotherapy for beneficiaries. This was also discussed during the CMS listening session, and while CMS is open to considering other options, they need a clear episode that can apply broadly. As of this time, CMS has found initiation of chemotherapy the best episode to use for this payment. We will keep an eye on the final model to see if this changes.
New PGP redesign activity
The Physician Group Practice (PGP) participant redesign activities remain the same as the OCM with one notable exception. CMS suggested a new 7th redesign activity that would require participating practices to gradually implement electronic patient-reported outcomes (ePROs). We know that capturing and managing ePROs in routine cancer care can increase time on therapy and improve patient outcomes through better symptom management. There were some comments during the listing session that expressed concerns about implementing ePROs, but Navigating Cancer is supportive of its inclusion.
Initially CMS requested all comments to be submitted by November 25, 2019. Several organizations, including COA, publicly stated that this was not enough time to review the proposal and submit comments. CMS listened to these comments and agreed to extend the comment deadline to December 13, 2019.
Navigating Cancer will be submitting comments to CMS on the proposal, particularly around our support of the ePRO redesign activity. We look forward to seeing the final OCF model and supporting our customers that choose to participate in the OCF.
Want to read more about the proposed OCF model? Check out these resources:
AJMC: Electronic PROs a Proposed Feature of Successor Model in Oncology Care
AJMC: CMS, CMMI Seek Feedback on Oncology Care First, Successor to OCM
Advisory Board: CMMI outlines potential next steps in oncology payment reform—the Oncology Care First Model