Tag Archives: CMMI Oncology Care Model

OCM Evolving Best Practices: Lessons to Date

By Monique J. Marino, Senior Manager, Publications & Content, ACCC

ThinkstockPhotos-507273299Last June, the Centers for Medicare & Medicaid Services (CMS) announced that nearly 200 physician group practices and 17 health insurance companies had been selected to participate in the Oncology Care Model (OCM), the first oncology-specific alternative payment model (APM) pilot. (According to the latest information on the OCM website, participant numbers now stand at 190 practices and 16 payers.)  At about 7 months into this brave new world, participants are beginning to share some lesson learned. At last week’s Cancer Center Business Summit in Las Vegas, a panel discussion on The Oncology Care Model: Evolving Best Practices, shed light on some of the challenges participants have experienced to date with the Center for Medicare and Medicaid Innovation (CMMI) model.

Panelist Diana Verrilli, Senior Vice President, Payer and Practice Management Solutions, McKesson Specialty Health, described the OCM as a “thoughtful and comprehensive model that is changing how people are being treated at our practices every day.” With 14 US Oncology practices—about 800 physicians—participating in the OCM, Verrilli shared three tangible outcomes that participants hope to see come out of the program: 1) a change in physician behavior, 2) improved use of clinical pathways, and 3) better patient outcomes, such as helping patients avoid hospitalizations.

OCM-related challenges that US Oncology practices have faced to date include:

  1. Developing processes to easily identify patients on oral oncolytics.
  2. Finding the resources and time required for practice transformation, for example, OCM participants are finding completion of the IOM care plan to be both time and staff intensive.
  3. Developing the complex care partnerships and pooling arrangements necessary to succeed under the OCM, e.g., adequate physician compensation.
  4. Creating processes and tools to needed to meet data submission and reporting requirements.

“If I could change one thing about the OCM,” Verrilli ended. “It would be to reduce the number of quality measures and the amount of documentation that is required.”

Fifty-five Flatiron practices across 20 states are also participating in the OCM. According to panelist Brenton Fargnoli, MD, Associate Medical Director Strategic Initiatives, Flatiron Health, challenges facing these practices relate to:

  1. Care management. How do you identify eligible patients? Keep track of data? Inform patients about their care plans—engaging and educating patients in their care.
  2. Program evaluation and reporting. How do you measure quality? Improve practice performance? Report to the OCM registry in the most cost-effective and efficient way possible?
  3. Revenue cycle management. How do you optimize practice income in the OCM model?

To meet these challenges, Flatiron is working with its practices to develop turnkey solutions, such as:

  1. Care management. Development of an e-process to do patient identification at point of care; Auto-generation of the IOM Care Plans in the EHR.
  2. Program evaluation and reporting. Structured data capture in the EHR; Auto-generation of an OCM Quality Measures Dashboard and OCM Registry reporting requirements.
  3. Revenue cycle management. Implementation of MEOS billing and collections tracking; Cost of care analytics.

When asked how the OCM could be improved, Dr. Fargnoli expressed sentiments similar to Verilli’s, “What’s working? Practices are very engaged and want to see the OCM model succeed. What’s not working as well—OCM rules and requirements are so complex that the majority of provider time is being spent on these documentation and reporting requirements.”

Finally, panelist Barbara McAneny, MD, Chief Executive Officer, New Mexico Oncology Hematology Consultants, shared concerns about the performance targets under the OCM, “If I could change one thing about the OCM, it would be the methodology by which the agency calculates targets so that practices can actually hit them. So how can CMS refine its targets? Give providers a year to collect the clinical data so that we can figure out why some patients are more expensive to treat than others. Using these data, we can work together to better refine OCM targets.”

For OCM participants interested in expanding the conversation, on Friday, March 31, 2017, ACCC is hosting the ACCC Oncology Care Model (OCM) Collaborative Workshop at the Renaissance Washington, DC, Downtown Hotel. Exclusively for OCM participants, the one-day event offers valuable, peer-to-peer learning with like-minded OCM professionals. The workshop will include snapshot presentations from OCM practices with innovative ideas and solutions for meeting OCM requirements, workgroups on hot topics, and a facilitated Q&A session. See registration details below.


The March 31, ACCC OCM Collaborative Workshop is an exclusive event for providers participating in the OCM. All attendees must pre-register for the OCM Collaborative Workshop through the CANCERSCAPE registration portal. To register, select the one-day OCM Workshop during registration checkout. Only those who are pre-registered for this workshop will be admitted. REGISTER TODAY.

Learn more about the ACCC OCM Collaborative here. This invitation-only platform provides a targeted discussion board and access to OCM-focused events. If your program is participating in the OCM and you have not received an invitation to join the ACCC OCM Collaborative, please fill out the form on the Collaborative Homepage to gain access to this peer-to-peer learning resource.

Medicare Oncology Care Model: Opportunities for Social Work Participation

By Fran Becker, LCSW, OSW-C

ThinkstockPhotos-467463476The oncology community continues to follow developments with the Center for Medicare and Medicaid Innovation (CMMI) Oncology Care Model (OCM), a program that aims to improve patient care, efficiency, effectiveness, and lower costs.

As participating cancer programs implement the changes mandated by the OCM, increased responsibilities for social work are clear.  In fact, under the model, the involvement of, and coordination with, social work is needed in a number of areas.

The OCM mandates that all patients receive patient navigation and supportive services during their treatment. These services encompass assistance in a number of areas, including financial, transportation, and facilitation of follow-up services.

As a component of the OCM, Medicare is requiring the documentation of a comprehensive Care Management Plan described in the National Academies (formerly, known as the Institute of Medicine) report, Delivering High-Quality Cancer Care: Charting a New Course for a System in Crisis. All patients are to receive a care plan consisting of 13 items.  Among these, there are two areas that call for social work services:

Advance Care Plans – Social work has been involved in these conversations for some time in many settings. In fact, Medicare has revised payment policies to include advance care planning (CPT code 99497; add-on CPT code 99498). While the physician is the primary provider in advance care planning conversations, members of the cancer care team, including social work and other allied healthcare professionals, have an opportunity to be involved in these conversations

Distress Screening – Another important requirement under the OCM is screening for depression during each episode of care. As part of the patient’s care plan, OCM participants are required to screen and document a plan to address a patient’s psychosocial health needs. While many cancer programs screen for distress using the NCCN Distress Thermometer, Medicare has determined that this tool is not sufficient to screen for depression under the OCM, and asks OCM participants to use the PHQ-2 and PHQ-9 for depression screening.  The PHQ-2 self-report asks two questions to determine if a more extensive evaluation is needed.  If the patient scores at a three or above, the patient is asked to complete the lengthier PHQ-9.  During this meeting, if the patient screens in for depression, social work involvement escalates.  Social work has several options for helping patients, including offering counseling services in-house or referral to an outside agency, referral to the patient’s primary care provider, oncologist, or a psychiatrist. Even if the program is providing clinical social work services, follow-up on these referrals is needed to ensure patients follow through. In addition, social work is required to follow the patient to assess improvement or the need for additional services.

Social workers play an important role in helping OCM participating programs succeed under this innovative new model. Practices that are not participating in the OCM should do a self-assessment in terms of their social work capabilities, and their ability to support patients’ psychosocial health needs. As signaled through CMMI’s inclusion of social work and patient navigation services in the OCM model, this holistic approach to cancer treatment is sure to be the future of oncology care.

If you are a participating OCM practice, be sure to join ACCC’s OCM Collaborative, an online community of OCM practices sharing best practices, tools, and tips to succeed in the OCM. Join today.


Guest blogger Fran Becker, LCSW, OSW-C, is manager of Cancer Support Services, Carl & Dorothy Bennett Cancer Center, Stamford Hospital, and a past member of the ACCC Board of Trustees.

Annual Meeting Highlight: Medicare Update & What to Expect in 2016

By Amanda Patton, ACCC Communications

ACCC 42nd Annual Meeting-ConwayAt the ACCC 42nd Annual Meeting last week, Lindsay Conway of The Advisory Board Company updated attendees on Medicare payments and what to expect in 2016.  Not surprisingly, her presentation touched on issues related to the meeting’s central themes of policy, quality, and value.

Two examples of the forward momentum in quality this year will be “testing” new oncology quality measures through PCHQR Quality Reporting Measures and CAHPS for Cancer Care.  Field testing for the CAHPS for Cancer Care is wrapping up, Conway said, and we can expect to see the CAHPS trademark on three oncology-specific surveys this summer.  Specifically, we will see a survey for surgical oncology, a survey for radiation oncology, and a medical oncology survey. Each survey will consist of about 85 questions and will likely reflect five CAPHS domains, including:

  1. Effective Communication
  2. Shared Decision Making
  3. Enabling Patient Self-Management
  4. Technical Communication
  5. Access

Looking ahead, Conway noted that new policies are supporting population health goals while also slowly moving forward with payment for value. As examples, she cited recent Medicare policies related to biosimilars, advance care planning, and lung cancer screening.

As cancer programs plan strategically for the future, Conway suggests keeping an eye on the following:

  • Payment equalization—which is gaining momentum
  • Progression of site-neutral payment policies
  • Physician practice acquisition—the equation is becoming increasingly complex from both the hospital and the physician practice perspectives
  • Alternative payment models (APMs), in particular the Center for Medicare and Medicaid Innovation (CMMI) Oncology Care Model.

The CMS OCM initiative, which will pilot a value-based reimbursement model in oncology, is on everyone’s radar screen, as the oncology community awaits the agency’s announcement of practices selected for participation. Conway acknowledged that the OCM model is complex and that many questions remain about how CMMI will implement the model.

The ultimate benefit for those participating in the OCM will not be financial, according to Conway. The benefits for participants will be strategic, e.g., new data sets, benchmarks, more data about the patients being served, the opportunity to develop competencies in operating in a risk-based environment, and having a voice in the development of new risk-based models in oncology.

Oncology Care Model: Updates from CMS

ThinkstockPhotos-469044147By Maureen Leddy, JD, Policy Coordinator, ACCC

As the clock ticks down to the May 7 deadline for CMMI Oncology Care Model (OCM) provider Letters of Intent (LOIs), some ACCC members may still be on the fence about submitting an LOI. CMS introduced the Oncology Care Model—the agency’s first specialty-specific alternative payment model—back in February. Those physician practices selected for OCM participation will begin receiving reimbursement for chemotherapy treatment episodes of care under the Oncology Care Model in spring 2016.

Since the introduction of the OCM, ACCC members have raised numerous questions as they weigh whether to apply for participation. In general, these questions have focused on three main issues: performance benchmarking methodology, payer collaboration, and the financial feasibility of achieving the practice transformation requirements. CMS has responded to some of these concerns, but we hope the agency will continue to provide clarity as the LOI submission period closes and our members prepare final applications for the June 18 deadline. Read on for a summary of CMS’s responses on these three key issues.

Performance Benchmarking Methodology

The initial Request for Applications (RFA) from CMS generated questions about the benchmarking methodology used to calculate a provider’s baseline or target price for specific episodes of care. Providers raised concerns about outliers with extremely high costs of care. CMS has responded that it will use Winsorization, resetting the outlying episode to a specific percentile within the provider’s total average care costs. Providers also raised concerns about how an already lean practice may benefit from OCM participation, where the benchmark for performance is based on the specific practice’s past performance. CMS has responded that the baseline period will likely be a three-year period beginning in 2012. The agency believes that this will help account for any very recent practice improvements. CMS has also indicated that the baseline for the entire five-year model will remain that same three-year period, ensuring practices that quickly adopt performance targets are not penalized in later years.

Payer Collaboration

In CMS’s applicant scoring methodology, participation with other payers (i.e., in addition to Medicare) will represent 30 points out of 100, a signal that the agency highly values the expansion of the OCM beyond Medicare. CMS has announced that 48 payers have submitted LOIs, and providers have raised concerns about whether to apply if no payer will be participating in their region. CMS has indicated that while it is an advantage for provider practices to partner with other payers, it is possible for a practice to be selected to participate in the OCM with only Medicare. There have also been indications that once the list of providers submitting LOIs is made public, there may be opportunity for payers to expand their participation regions.

Financial Feasibility

ACCC members have also raised concerns about whether the $160 per beneficiary per month fee is sufficient to achieve all of the practice transformations called for in the OCM. CMS has noted that other payers are expected to provide enhanced payments, which can also be used for the infrastructure changes called for in the OCM. For patients that do not fall within the OCM, practices may also continue to bill for chronic care management and transitional care management. CMS believes that this will provide sufficient revenue to support the required infrastructure changes. However, ACCC welcomes further feedback from members.

As we enter the post-SGR era, ACCC will be working to keep members informed on alternative payment model initiatives. We are pleased to hear that several members will apply to participate in the CMMI Oncology Care Model, and will continue to provide updates on this and other relevant alternative payment models as details become available.

Questions or comments on the OCM? Contact us at ocm@accc-cancer.org or visit our Oncology Care Model Resource Center.

SGR is Over: What Does it Mean for Providers?

By Maureen Leddy, Policy Coordinator, ACCC

U.S. Capitol On April 14, 2015, after years of uncertainty and 17 short-term “doc fix” patches to prevent severe annual cuts to physician payments, Congress approved H.R. 2, Medicare Access and CHIP Reauthorization Act (MACRA). This bipartisan, bicameral compromise finally puts an end to the sustainable growth rate (SGR) formula. MACRA provides physicians with the predictability in payments needed to continue to provide high-quality cancer care, while transitioning over a 10-year period to a new dual Medicare reimbursement system.

What’s in Store?

Under MACRA physicians must eventually participate in a Merit-Based Incentive Payment System (MIPS) or an Alternative Payment Model System. Through June 2015, MACRA calls for Medicare physician reimbursement at the rate set by last year’s “doc fix” patch. Then, for five years, through 2019, annual 0.5% increases to payment rates are established.

In 2020, a second five-year phase begins during which reimbursement rates remain flat. During this second phase, providers will need to transition to the Merit-Based or Alternative Payment Model Systems. Ultimately MACRA encourages providers to participate in Alternative Payment Model Systems through higher incentive payments; beginning in 2026, physicians will receive automatic payment updates of 0.75% if participating in an APM, and 0.25% if participating in MIPS, with an opportunity to receive additional bonus payments based on performance. Payments under the MIPS will be subject to positive or negative adjustments based on the following performance criteria:

  • quality of care
  • resource use
  • clinical practice improvement activities
  • use of electronic health records (EHR) technology.

During the second five-year phase through 2024, providers participating in an Alternative Payment Model will  be eligible for annual lump-sum bonuses equaling 5% of the prior year’s payments upon achieving specified targets in transitioning from fee-for-service payments.  Providers participating in MIPS will be eligible during this second five-year period for additional positive adjustments in rates for exceptional performance.

Payment Model Technical Advisory Committee

MACRA encourages the development of Alternative Payment Models applicable to specialties and small practices, as well as models that align private and state-based payers. The legislation calls for creation of a Payment Model Technical Advisory Committee that will recommend additional Alternative Payment Models to CMS. CMMI’s recently launched Oncology Care Model (OCM) already provides one venue for many cancer providers to participate in an Alternative Payment Model. Visit ACCC’s Oncology Care Model Resource Center for answers to providers’ questions on eligibility, reimbursement, and key considerations for participation in this new payment model, plus links to application forms and CMMI OCM materials.

Going forward, ACCC will be vigilantly monitoring the Payment Model Technical Advisory Committee recommendations for other Alternative Payment Models that may be relevant to oncology practices.

ACCC looks forward to working with our members to effectively implement the bill and transition towards a new future for physician reimbursement.

On Wednesday, April 22, ACCC is hosting a members-only conference call with presenter Dan Todd, former Senior Health Counsel, Senate Finance Committee, and a primary author of MACRA, that will provide an in-depth look at what MACRA means for oncology providers and the future of physician reimbursement. ACCC members can access call-in information here.

Stay tuned.

Bringing the Oncology Care Model into Focus

By Leah Ralph, Manager, Provider Economics and Public Policy, ACCC

imagesAs ACCC members are well aware, on February 12, the CMS Innovation Center (CMMI) released its much-anticipated Oncology Care Model (OCM) as part of the broader effort to lower healthcare costs and tie reimbursement to quality and value. ACCC has been conducting an in-depth analysis, and, overall, the OCM generally resembles the discussion draft we saw in August; while the model contains many positive elements, other areas still need clarification.

At its core, the OCM looks similar to a patient-centered oncology medical home or accountable care organization (ACO), with a target expenditure and shared savings component that encompasses the total cost of patient care during a particular period of treatment. The model is a voluntary, five-year program slated to begin in spring 2016. Physician group practices, hospital-based practices (except for PPS-exempt hospitals), and solo practitioners that furnish cancer chemotherapy are eligible to participate. Payments will be based on a six-month episode of chemotherapy treatment that is triggered by the administration of a pre-set list of chemotherapy drugs, and will take into account all Part A, Part B, and some Part D expenditures for that patient during the episode. In addition to a FFS payment, providers will receive a care coordination payment to improve quality of care ($160 per patient, per month during the episode) and a performance-based payment to incentivize lower costs that will be based on the difference between a risk-adjusted target price and actual expenditures during the episode. The payment arrangement is one-sided risk, with the option of converting to two-sided risk in the third year.

Importantly, the OCM is a multi-payer model in which commercial payers and state Medicaid agencies are encouraged to participate. Aligning financial incentives by engaging multiple payers will leverage the opportunity to transform oncology care across a broader population. During the selection process, CMMI will favor practices that participate with other payers in addition to Medicare. In addition, practices will have to meet certain quality metrics and undergo practice transformation requirements, including: effective use of electronic health records; 24-hour access to practitioners who can consult the patient’s medical record in real time; comprehensive patient care plans; patient navigators; and continuous quality improvement.

While we were pleased to see much of ACCC’s feedback incorporated in the final version, our dialogue with CMS is ongoing. Our members continue to have questions about the benchmarking methodology, specifics on the quality metrics and practice transformation requirements, eligibility to participate in the model, and more. ACCC will continue to seek answers to these questions, and will offer CMS feedback based on member input.

If your practice is interested in participating, or considering participation, we encourage you to submit a non-binding letter of intent to CMS by the deadline of April 23, 2015. We anticipate CMS will continue to provide additional guidance until the application deadline, which is June 18, 2015.

Join us at ACCC’s Annual Meeting CANCERSCAPE on March 17 and hear directly from Ron Kline, MD, Medical Officer with the Center for Medicare and Medicaid Innovation—an author of the Oncology Care Model, as he shares an insider’s perspective on New Payment and Delivery Models in Medicare.

Transformation ⇒ From Volume to Value

Centers_for_Medicare_and_Medicaid_Services_logoBy Leah Ralph, Manager, Provider Economics and Public Policy, ACCC

This week the CMS Innovation Center announced the launch of the Oncology Care Model—the agency’s newest payment and service delivery model, described as a multi-payer, oncology practitioner-focused model designed to improve the quality of cancer care while lowering cost.

According to the CMS announcement, key facets of the model include:

  • Episode-based payment that targets chemotherapy and related care during a six-month period following the start of chemotherapy treatment.
  • Multi-payer design with Medicare fee-for-service and other payers working in tandem to promote care redesign for oncology patients.
  • Requiring physician practices to engage in practice transformation to improve quality and coordination of care.

This is the latest signal that the shift from volume-based reimbursement to payment for value and quality is gaining momentum. The interest in moving healthcare payment away from a system that incentivizes quantity has been reflected in every major healthcare law in recent years—from the Medicare Modernization Act (MMA) in 2003 to the Affordable Care Act (ACA) in 2010.

In fact, the ACA created the $10 billion Center for Medicare and Medicaid Innovation (CMMI) with the sole aim of developing and testing innovative ways to pay providers. And on Feb. 12 the Innovation Center provided its first model for oncology care.

The launch of this model is not unexpected given that in January 2015, for the first time in Medicare’s history, the Department of Health and Human Services (HHS) announced explicit goals for tying Medicare payments to alternative payment models and value-based payments. According to the HHS timeline, 30 percent of all fee-for-service (FFS) Medicare payments will be tied to alternative payment models by 2016—including, but not limited to, Accountable Care Organizations (ACOs), medical homes, and bundled payments for episodes of care. By 2018, 50 percent of payments will be tied to these models. CMS also set a goal of tying 85 percent of traditional Medicare payments to quality or value by 2016 and 90 percent by 2018 through such programs as the Hospital Value Based Purchasing or Hospital Readmissions Reduction programs.

Ambitious Goals

The initial benchmark of 2016 sets a laudable, but ambitious, goal. Certainly the announcement signals the Obama Administration is making this issue a priority, and we can expect to see an accelerated push to transition Medicare payments and, in turn, private payers.

This shift is a huge undertaking that will not only affect payments, but fundamentally change incentives for how providers deliver care. Implementation will take time, and will require the right balance of forward momentum and important safeguards to ensure that patients continue to receive the most appropriate, quality care. As HHS moves full steam ahead, the provider community must speak up and urge policymakers to:

  • continue to work to find consensus on appropriate quality measures,
  • establish a sound, fair methodology for calculating financial benchmarks and risk adjustment, and
  • allow providers the time, resources, and flexibility they need to implement these new payment models.

The just-announced Oncology Care Model (OCM) will test the bundling of payments for chemotherapy administration. But with other models, such as the Medicare Shared Savings Program (Medicare ACOs) that are primary care focused, it’s still unclear how oncologists will be included or even participate. Caring for cancer patients is complex and often expensive, leaving inherent challenges in how to account for cancer care in alternative models. How will high-cost drugs and innovative therapies be treated in the construct of an ACO? Will high-cost cancer patients be included in the financial benchmark? What is oncology’s role in shared risk and savings? ACCC and other organizations are continuing to work with CMS to answer these questions.

Call to Action

ACCC encourages the provider community to remain informed and active participants in the policy-making dialogue to ensure that we do, in fact, achieve meaningful, realistic payment reform. One of the best ways to get engaged is meeting with your legislators at ACCC’s upcoming Capitol Hill Day on March 16. The next day, at ACCC’s Annual Meeting, CANCERSCAPE on March 17, we’ll be hearing from Ron Kline, MD, Medical Officer with the Center for Medicare and Medicaid Innovation – an author of the Oncology Care Model. Now is the time to come to Washington D.C. – get your questions answered and voices heard at a pivotal moment for oncology care. Join us!