Tag Archives: value-based payment

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.

Fasten Your Seat Belts. . .

By Leah Ralph, Director of Health Policy, ACCC

Overlapping roadways As we head into the New Year, 2016 is rapidly receding in the rear view mirror. Still, it was quite a year. We saw the Obama Administration finalize regulations for sweeping physician payment reform in Medicare, oncology practices nationwide navigate the first year of the Oncology Care Model (OCM), policymakers try – and fail – to push through drug pricing reform with a national mandatory demonstration program, the 21st Century Cures Act signed into law, and the drug pricing debate hit a fever pitch, fueled by public scrutiny of recent spikes in drug spending and prompting a range of policy proposals to reduce spending on pharmaceuticals, raising bigger questions about how to define value in cancer care.

And after nearly eight years of a healthcare system shifting to achieve the aims – and requirements – of President Obama’s signature health reform law, the surprise election of Donald Trump and transition to a Republican administration and Congress who have prioritized repealing the Affordable Care Act (ACA) in early 2017 – combined with unprecedentedly thin policy prescriptions on the campaign trail – mark the beginning of an uncertain, tumultuous, perhaps even bumpy period for health policy. And fasten your seat belts because it may happen fast: the first 18 months of a new presidency and congress is the most active period of policymaking in the U.S.

ACA’s Uncertain Future

With respect to the ACA, while the health reform law encompasses far more than the insurance exchanges, the public debate to date has been focused on the coverage mandate and subsidies in the individual marketplace. It’s important to note that regardless of the election results, the health insurance exchanges are doing worse than expected. The exchange markets are facing sicker-than-expected risk pools and lower enrollment, causing high premium increases and insurer withdrawals. To survive, the exchanges would have needed stabilization under any administration – meaning a Trump Administration could simply leave the exchanges untouched and effectively allow them to wither on the vine, leaving 20 million uninsured.

But President-Elect Trump has signaled that he favors politically popular consumer protections in the ACA, such as banning insurers from discriminating against people with pre-existing conditions and allowing children to remain on their parents’ health plan until age 26. However the path to achieve this without a requirement that individuals either obtain coverage or pay a penalty remains unclear. And while there’s no agreed-upon replacement plan, Congressional Republicans have also supported allowing the sale of health insurance across state lines, expanding the use of health savings accounts (HSAs), replacing the ACA’s health insurance subsidies with tax credits, and establishing high-risk pools. But none of these proposals would meaningfully restore access to insurance coverage for the more than 20 million people who have gained coverage under the ACA, creating a long road ahead to find ways to cover this newly expanded population in any replacement plan.

What will these changes mean for cancer patients and providers? While the scope and details remain unclear, generally, under the proposals put forward to date, cancer providers may see an increased number of patients who are under- or uninsured, and higher uncompensated care costs. For the exchange population, benefits and cost-sharing assistance will likely be less generous, which could pose significant access barriers to quality cancer care.  At the same time it’s important to note that the ACA overpromised and underperformed – while patients without access to subsidies are seeing out-of-pocket costs spike, concurrently providers’ expectations of gaining fully insured patients under the ACA have not necessarily been realized. Patients with exchange coverage have generally been sicker and more expensive to treat and, on top of that, some providers are starting to see their Disproportionate Share Hospital (DSH) payments evaporate, as agreed to under the law. Fixes to the ACA – beyond what Republicans are proposing – are needed to shore up the long-term viability of our healthcare system for both patients and providers.

The Path Ahead

As the New Year rings in the changes in Washington, D.C., there will undoubtedly be significant impact on the direction of federal policy with respect to access and coverage in 2017. Still, we expect that key market trends such as value-based purchasing will continue. While the fate of the Center for Medicare and Medicaid Innovation (CMMI), which was created by the ACA, remains uncertain, we suspect that Medicare’s push towards value-based payment is inherently non-partisan and the movement to test different ways to pay providers based on cost and quality is here to stay. In fact, many experts predict that 2017 will be the year value-based purchasing moves from concept to reality. CMMI has implemented more than 50 demonstration programs. Some of these are becoming mandatory, including bundled payments for cardiac care and joint replacement.  (At the same time, the Republican-controlled Congress may create some guardrails for CMMI, including limiting its ability to implement mandatory demonstrations.)  Just around the corner, Medicare physician payment is shifting from fee-for-service (FFS) to value-based purchasing as required under MACRA . Reporting on MACRA measures begins in 2017 and will determine provider Medicare reimbursement in 2019. And the pharmaceutical industry is also engaged in value-based purchasing, increasingly pursuing outcomes-based contracts with private plans.

Where the Rubber Meets the Road

In 2017, ACCC members will need to consider how value-based payments will increasingly shift responsibility for managing cost and quality to providers, and how your cancer program is positioned to engage in a risk-based reimbursement structure. Providers should also prepare for a shift in coverage for patients, and anticipate how to respond to changes in access to care.

Now more than ever is the time for oncology care providers’ voices to be heard – join us in Washington, D.C., March 29-31 for ACCC’s annual policy meeting, Cancerscape, to understand how policy changes will impact your program and patients, engage in policy discussions with your colleagues, and help shape the future of healthcare policy in 2017 and beyond.  So buckle up, check out the Cancerscape agenda, and register today.

MACRA Update—Will CMS Delay the Start Date?

By Brittney Fairman, Policy Analyst, ACCC

Calendar pages and clockLast week Andy Slavitt, Acting Administrator for the Centers for Medicare & Medicaid Services (CMS), told the Senate Finance Committee that the agency was considering “alternative start dates,” for Medicare Access and CHIP Reauthorization Act (MACRA) after receiving more than 3,000 comments on its proposed rule implementing the Quality Payment Program. The final rule is expected in November, leaving only a few months before the proposed reporting start date of January 1, 2017. Slavitt also said the agency is taking a close look at how the proposed rule would impact rural and small providers, particularly the low volume threshold that would exempt small practices from certain reporting requirements.

In our June 27 comment letter on the MACRA proposed rule, ACCC urged CMS to:

  • Delay implementation for six months to one year, to give physicians the time needed to build infrastructure and implement the Quality Payment Program effectively
  • Ensure that the agency provides adequate accommodations and protections for small group practices and solo practitioners
  • Modify the “resource use” methodology to ensure that eligible clinicians are held responsible only for the costs they can control
  • Include all Oncology Care Model (OCM) quality measures in MIPS
  • Refine the APM requirements to offer a meaningful alternative to MIPS and adopt policies to promote the availability of a wide variety of APMs and Physician-Focused Payment Models (PFPMs).

With this proposed rule, CMS aims to transition Medicare to a new physician payment program focused on quality, value, and accountability over volume. The MACRA legislation enacted by Congress outlines essentially two separate payment pathways for physicians under Medicare: The Merit-Based Incentive Payment System (MIPS), and the Alternative Payment Models (APMs). Both pathways are intended to drive the development of value-based payment. ACCC supports payment reform efforts; however, it is critical that CMS construct these pathways so that they are realistic, achievable avenues to Part B reimbursement.

ACCC will continue to keep members informed as MACRA implementation unfolds. For a deeper dive on new requirements under the Quality Payment Program, ACCC members can access the recent ACCC webinar, “MACRA CMS Proposed Rule: What You Need to Know” on demand (login required). The American Medical Association (AMA) has created a MACRA Checklist that outlines steps providers can take now to prepare, as we await the final rule.