Tag Archives: OCM

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.

With Final MACRA Rule, CMS Increases Flexibility

By Leah Ralph, Director of Health Policy, ACCC

Healthcare costsOn Friday, October 14, the Centers for Medicare & Medicaid Services (CMS) released its final rule on the MACRA Quality Payment Program (QPP).  ACCC is conducting an in-depth analysis of the rule; however, an initial look reveals that CMS has heard the stakeholders’ message  loud and clear: Make the transition to MACRA as simple and flexible as possible. Here are some top-level highlights from the final rule:

  • Low-volume threshold exemption: the agency broadened the low-volume threshold exemption from the Merit-Based Incentive Payment System (MIPS), exempting practices with less than $30,000 in Medicare charges or fewer than 100 unique Medicare patients per year. This will exclude about one-third of physicians from having to report under the Quality Payment Program (QPP).
  • Pick your pace: CMS is allowing physicians to “pick their pace” in 2017, enabling physicians to avoid negative penalties in 2019 by reporting on some data (i.e., one quality measure) for some period of time. The takeaway: even minimal performance reporting will exempt physicians from any penalties, and opportunities for a shorter, 90-day reporting period will make providers eligible for positive adjustments. (Providers must start collecting data between January 1, 2017, and October  2, 2017, and report no later than March 31, 2018.)
  • Resource use category weighted zero in first year: MIPS has four components, and originally the resource use (cost) category was going to account for 10% of your score starting in 2017. CMS has now said this category will hold zero percent weight toward your MIPS score in the first year [in 2017, the percentages will be: 60% quality measures, 25% advancing care information (EHR use), and 15% clinical improvement activities].
  • Expanding opportunities to participate in APMs: CMS has also said it plans to expand opportunities to participate in models that qualify as “advanced alternative payment models” (APMs) in 2017 and 2018. The Center for Medicare and Medicaid Innovation (CMMI) also informed Oncology Care Model (OCM) practices on Friday, October 14, that CMS is amending the program to allow OCM practices to take two-sided risk as early as January 2017 to qualify as an advanced APM (two years earlier than the model originally allowed).

In our comments on the proposed rule, ACCC asked for increased flexibility for practices who are still building the infrastructure to meet these requirements, and a streamlining of reporting requirements as our members increasingly engage in new delivery models and navigate the path to value-based care. ACCC’s major concerns were around timeline and administrative burden – in the final rule, CMS was responsive in many ways, but ACCC will continue to work with the agency to reduce regulatory burden and make this a workable payment system for our members.

For more information, CMS launched a website for physicians that explains the program and allows you to explore and identify different measures that are most meaningful to your practice. Find a summary of the rule here. The AMA and ASCO also have great checklists on how to prepare for participation in the QPP.

 

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.

CANCERSCAPE Session on OCM Brings Insights

by Amanda Patton, ACCC Communications

20150317_ACCC_41st_190On Tuesday, March 17, at ACCC’s Annual Meeting, Ron Kline, MD, Medical Officer with the Center for Medicare and Medicaid Innovation (CMMI), and Kavita Patel, MD, MS, of the Brookings Institution helped bring a little more clarity to CMMI’s Medicare’s Oncology Care Model (OCM).

The OCM has been developed by CMMI to test new payment and service delivery models, as part of its overarching triple aim of better care, smarter spending, and healthier people. OCM goals center on care coordination; appropriateness of care; and access for beneficiaries going through chemotherapy, Dr. Kline said. Learn more here.

In his overview of the five-year pilot, Dr. Kline pointed to the multi-payer nature of the OCM. “Payers are encouraged to work as part of the model. The point is to leverage the OCM to bring in more and more payers and patients to this model.”

Finally, he stressed the OCM is not intended to be a one-size-fits-all model.

“Part of the point of OCM is that we don’t have all the right answers for all the parts of the country…and the best way to move forward is to learn best practices [through the model].”

CMMI plans to hold webinars, site visits, and meetings at ASCO and elsewhere to share OCM best practices, he said.

So, What’s Everyone Asking?

According to Dr. Patel, the top OCM hot topics are:

# 1 Eligibility. CMMI wants the OCM to “include everyone as much as possible as long as we adhere to the principles of the OCM, attribute, and benchmark appropriately,” said Dr. Kline.

“ACCC is exactly the audience the Oncology Care Model is tailored for—those providing ongoing services for cancer care,” said Dr. Patel.

#2 If you have a practice, can only some providers participate? The short answer is, if you participate, anyone in the practice who is prescribing chemotherapy would be automatically included in the OCM. This includes NPs or PAs who might be prescribing. Simply put: It’s an inclusive model.

#3 Data requirements. Participants need the administrative and technological resources to support these.

For those contemplating OCM participation Patel suggests the following steps:

  • Evaluate what infrastructure investment you will need to make.
  • Perform a serious “gut check” with providers on what OCM participation will mean.
  • Consider how you’ll get all those involved in the OCM to understand the model’s total cost of care framework. (This last item is likely the biggest organizational hurdle, Patel said.)
  • Finally, consider the staffing requirements for participation.

What components will be needed for OCM success? Dr. Patel identified three:

  • Bringing on primary care physicians
  • Learning how to do robust data exchange inside the practice, e.g., having an EMR able to deliver clinicians what they need at point of service
  • Being able to predict which patients in your population will need more intensive services (risk stratify).

Perhaps it’s not surprising that even during the OCM discussion, the SGR made a cameo appearance. Dr. Patel noted that details of an SGR fix currently being negotiated on Capitol Hill will likely include some provisions that will force doctors to enter into alternative payment models in the next five years.

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.