The Center for Medicare and Medicaid Innovation’s (CMMI) says that 67 oncology physician group practices nationwide will participate in its new, voluntary Enhancing Oncology Model (EOM) that is launching July 1. EOM includes two risk arrangements with differing levels of downside risk.
Across the 67 practice participants, there are over 600 sites of care representing approximately 37 states nationally and over 3,000 unique practitioners, according to CMMI. Approximately 15 percent of EOM participants’ sites of care are located in a rural/small town/micropolitan areas. A little over half of EOM participants having previously participated in the Oncology Care Model (OCM).
EOM is a 5-year voluntary model that aims to improve quality and reduce costs through payment incentives and required participant redesign activities. It is designed to test how best to place cancer patients at the center of the care team that provides high-value, equitable, evidence-based care. EOM aims to improve care coordination, quality, and health outcomes for patients while also holding oncology practices accountable for the total cost of care.
Earlier this month, an online survey conducted by the nonprofit Community Oncology Alliance (COA) suggested that the majority of independent oncology practices were not planning to participate in the EOM. COA said the survey results raise serious questions about the unpredictability of the model and risks faced by practices.
The COA survey gathered responses from 137 oncology practices across the United States. COA noted that 61 percent (83 practices) of the respondents had participated in the Oncology Care Model (OCM), the previous CMMI oncology payment reform model. The majority of total survey respondents (91 practices or 71 percent of respondents) indicated that they would not be participating in the EOM. Also, 64 percent (88 practices) of the respondents submitted an EOM letter of intent to CMMI; however, only 29 percent (40 practices) actually plan to participate.
CMMI said the model’s design incorporates many of the lessons that CMS learned from the OCM and feedback from the oncology community, including from OCM participants, patient advocacy groups, oncology professional associations, and others. Like OCM before it, EOM is a multi-payer model that aims to promote a consistent approach across payers and EOM participants’ patient populations.
EOM also includes a focus on improving health equity, another top priority for the CMS Innovation Center. The health equity strategy for EOM requires participating oncology practices to screen for health-related social needs (HRSNs), introduces data reports on expenditure and utilization patterns of each participant’s patient population to help participating professionals identify and address health disparities, and offers an additional payment for the provision of Enhanced Services to patients who are dually eligible for Medicare and Medicaid. These additional payments for dually eligible patients are not included in the practices’ total cost of care responsibility. EOM participants will ask patients to routinely report their symptoms in order to encourage better communication and a more proactive care response, and EOM participants are required to submit plans to CMS outlining how they will promote health equity.
Under EOM, participating Physician Group Practices (PGPs) take on accountability for their patients’ healthcare quality and for total spending during six-month episodes of care for Medicare patients with certain cancers.
CMS provides participants the option to bill for a Monthly Enhanced Oncology Services (MEOS) payment for Enhanced Services provided to eligible beneficiaries. The MEOS payment is higher for beneficiaries dually eligible for Medicare and Medicaid.
EOM participants have the opportunity to earn a retrospective performance-based payment (PBP) based on quality and savings. Participants are required to take on downside risk from the start of the model (with the potential to owe CMS a performance-based recoupment).
EOM participants are required to implement participant redesign activities, including 24/7 access to care, patient navigation, care planning, use of evidence-based guidelines, use of electronic Patient Reported Outcomes (ePROs), screening for health-related social needs, use of data for quality improvement, and use of certified electronic health record technology.
EOM focuses on beneficiaries receiving systemic chemotherapy (that is, not beneficiaries receiving hormonal therapy only) for seven cancer types: breast cancer, chronic leukemia, small intestine/colorectal cancer, lung cancer, lymphoma, multiple myeloma, and prostate cancer.
Quality Payment Program (QPP)
EOM includes two risk arrangements with differing levels of downside risk. Both EOM risk arrangements qualify as a Merit-based Incentive Payment System (MIPS) Alternative Payment Model (APM) under the QPP beginning in July 2023. The risk arrangement with increased downside risk (EOM’s Risk Arrangement 2) meets the criteria under 42 CFR § 414.1415 to be an Advanced APM under the QPP beginning in July 2023. Advanced APM participation allows a clinician the opportunity to achieve Qualifying APM Participant (QP) status and be excluded from the MIPS reporting requirements and payment adjustments. Clinicians in an Advanced APM that do not achieve QP status are subject to the MIPS reporting requirements and payment adjustments.