ACCC Statement on the Enhancing Oncology Model

The Association of Community Cancer Centers (ACCC) is pleased that the Centers for Medicare & Medicaid Services (CMS) has announced a new, voluntary alternative payment model as a successor to the Oncology Care Model (OCM), which is due to sunset later this month. We are hopeful that the Enhancing Oncology Model (EOM) will allow ACCC programs and practices to progress in their value-based care transformation journeys and continue to deliver high-quality, equitable, and affordable cancer care to the communities they serve.

ACCC appreciates that CMS has made participation in EOM voluntary, and that the agency has taken feedback from ACCC and its members participating in OCM to make improvements to the price prediction models and attribution methodology for this new model. We also applaud the model’s focus on improving health equity by requiring participants to implement new redesign activities, such as screening patients for social needs and developing health equity plans to mitigate disparities within their own patient populations. These initiatives align well with the Administration’s efforts to address inequities as part of President Biden’s renewed Cancer Moonshot, and the model provides a fresh opportunity to reach additional patients in underserved and under-resourced communities. 

At the same time, we are concerned with some of the structural elements of the program. For example, the requirement for participants to accept downside risk from the start of the model will be a significant barrier to enrollment given the current reimbursement landscape. Two-sided risk models may not make financial sense for smaller oncology programs, particularly those who care for underserved patients and those that have not previously participated in OCM. CMS should endeavor to provide as much information on proposed payment methodologies, cost data, and benchmark amounts as early as possible so that practices can make informed decisions around participation.

ACCC stands ready to support CMS in the implementation of this new model. We are eager to work with our members to ensure that EOM can be successful in improving care coordination, quality, equity, and outcomes for patients, while managing the total cost of oncology care.