CMS to Move Forward with The Oncology Care First Model
The Oncology Care First Model (OCF) is poised to continue the progress, feedback, and lessons learned from its current predecessor, the Oncology Care Model (OCM).
Since 2013, Carevive has been aligned in supporting value-based care to enable improved care coordination, appropriateness of care, and access to care for beneficiaries undergoing chemotherapy. The Carevive platform was built by oncology experts and is used in leading cancer programs across the United States for personalized treatment care planning, symptom monitoring and management, care coordination, and survivorship care.
In addition, Carevive health system customers use our software to collect meaningful, real-world patient experience data (PED) that will be used to inform new drug development and meet post-approval regulatory requirements demonstrating long-term efficacy and safety.
The value-based program we most commonly support is CMS’ first alternative payment model: The Oncology Care Model (OCM). On November 1, 2019, CMS introduced the next generation oncology value-based payment model to succeed OCM: the Oncology Care First (OCF) Model.
Approximately 1,800 accredited cancer programs in the U.S are eligible to participate in this program. We are seeing high interest among providers to participate in the new OCF program, because of the benefits that OCM has already demonstrated. CMS’ funding for practice transformation provides the opportunity for the cancer provider community to prepare for value-based care.
CMS held a public session on November 4, 2019, to provide interested parties the opportunity to provide comments on the proposed re-design activities and payment methodology. Numerous provider group participants commended CMS for the design of OCF and CMS’ commitment to providing financial reimbursement for practices committed to better quality, patient-centered, value-based care delivery models.
Oncology Care First Model (OCF) Re-Design Activities
By transitioning to the new OCF model, CMS aims to build on the lessons learned with OCM. These include but are not limited to an increasingly positive impact on acute care utilization and quality of care, including at the end of life (e.g., fewer inpatient admissions and Intensive Care Unit stays in the last month of life).
Our customers have published case studies showing reductions in avoidable ED visits/hospitalizations of close to 15%, which they attribute to practice re-design activities. The OCF Model will require participants to continue to offer the following redesign activities believed to be critical for high-quality cancer care for all Medicare patients, including:
- offering patients 24/7 access to a clinician with real-time access to their medical records
- providing the core functions of patient navigation
- documenting a care plan for each patient that contains the 13 components of the Institute of Medicine’s (IOM) Care Management Plan
- treating patients with therapies consistent with nationally recognized clinical guidelines
- using Certified Electronic Health Record Technology (CEHRT)
- utilizing data for continuous quality improvement
- gradually implement electronic patient-reported outcomes (ePROs)
Much aligned to our mission, CMS is requiring a gradual implementation of electronic patient-reported outcomes (ePROs).
Dr. Ethan Basch, a pioneer in oncology ePROs and Carevive’s Scientific Advisory Board Director stated, “It is laudable that electronic PROs are a foundational tenet of the proposed OCF alternative payment model. This is the fruition of research showing clinical and utilization benefits when PROs are integrated into clinical oncology practice.”
A 766-patient study led by Ethan Basch, published in the Journal of Clinical Oncology and Journal of the American Medical Association, showed improvements in quality of life and adherence to therapy, reductions in hospitalizations and ER admissions, and improved survival for patients using a patient-reported symptom monitoring system similar to Carevive’s PROmpt® product.
Carevive supports EHR data and embedded workflow integration to enable clinician users to leverage Carevive ePRO technologies in the context of patients’ electronic health records.
Payment Methodology
CMS will provide Prospective Monthly Payments for all Medicare patients to support practice transformation and the delivery of these required enhanced services. These include a typical fee-for-service reimbursement for patient management plus funding for the delivery of enhanced services. Additionally, this includes an administration component (e.g. drug administration services, E&M payments to hospital outpatient departments where applicable).
Total episode expenditures for patients will be reconciled against a benchmark or target amount, with the possibility of receiving a performance-based payment on top of Prospective Monthly Payments. The monthly performance payments will be determined based on patient population risk. For a limited time, there will likely be an only one-sided risk for those who did not participate in OCM to allow new sites to familiarize themselves with the new program.
At the public session, providers urged CMS to consider offering one-sided risk for all participants, regardless of whether or not they have participated in OCM. There was significant discussion about two-sided risk, which is being contemplated, due to the numerous data points that OCM sites are sharing that support improved outcomes when risk is shared.
CMS is also seeking multi-payer partnerships to align incentives across a participating practice’s entire patient population. Providers do not need to differentiate approaches for caring for their Medicare fee-for-serve (FFS) population with multi-payer partnerships compared to their other patients.
The Relationship with Oncology Care First Model (OCF), Carevive OPT-IN™ & PED Registries
Carevive OPT-IN™ (Oncology Pragmatic Trial Investigator Network) is a network of Carevive customers participating in tumor registries to collect real-world experience data. Participants in OPT-IN receive access to aggregated Patient Experience Data and benchmarking for continuous practice improvement. OPT-IN funding also helps participants acquire technology needed to meet OCF practice re-design requirements.
CMS/private payers and other stakeholders in cancer care delivery, particularly the life science industry, have a significant interest in having access to Carevive’s 16 PED registries. Patient Experience Data is becoming increasingly important to Congress and regulatory agencies to inform better drug development. There is growing interest in including such data in New Drug Applications (NDA/BLAs).
There is also interest in using these data to provide data on long-term value and safety of novel cell and gene therapies. The initial PED registries (breast, prostate, ovarian, and lung cancer, and multiple myeloma) are planned to be available for commercial license in 2021. The OCF program supports the accelerated contribution of our practices’ complete datasets to these registries, as there is now the added benefit of OCF requiring ePROs collection, and the belief that its collection will improve practice performance and associated performance payments.
Aside from the benefits of raw PED collection, life sciences are also interested in supporting providers as they embark on delivering value-based care.
In summary, Carevive strongly supports CMS’ announcement of the OCF Model. We believe this program provides an invaluable opportunity for U.S.-based cancer programs to transform their practice in delivering better quality, patient-centered, value-based care.
As OCM/OCF programs mature, Carevive is committed to continuously building upon and refining our care management, patient engagement technologies, and our PED registries. This allows Carevive to fulfill our mission to markedly improve cancer care delivery and drug development that will result in better outcomes for cancer patients and their families.
Last update: July 1, 2021
