In our recent Reflections on the Oncology Care Model (OCM) webinar, three panelists discussed their experiences participating in the OCM and their thoughts on CMS' new Enhancing Oncology Model (EOM). Here are four key factors they're considering in deciding whether to participate in the EOM:
1. Previous OCM participation will make it easier to participate in the EOM
Participants in the EOM will start out with downside risk. While practices that participated in two-sided risk in the OCM will be prepared to take on risk, other practices may find this aspect of participating in the EOM more daunting.
In addition, OCM participants have already implemented many of the EOM requirements, such as providing patient navigation, adhering to clinical guidelines, offering 24/7 access to clinicians, and documenting care plans. This means they will be able to fulfill the EOM requirements without significant changes to their current care processes.
Non-OCM participants will have more work to do to implement the changes required to succeed in the EOM. Practices run the risk of accruing financial penalties for not meeting requirements during the first few performance periods, depending on how quickly they're able to implement the requirements.
2. Practices that decide not to participate in the EOM must still participate in MIPS reporting
Foregoing EOM participation doesn't mean that providers will be off the hook for quality and cost measures. Oncology practices that join the EOM will likely be considered to be participating in a MIPS alternative payment model (APM) if they enroll in risk arrangement 1 or an Advanced APM if they enroll in risk arrangement 2.
Oncology practices that don't participate in the EOM will have to participate in MIPS reporting instead, which comes with its own set of operational and financial considerations. Practices must consider these trade-offs when deciding between MIPS reporting and EOM participation.
To complicate this decision, CMS also recently proposed a new, oncology-specific MIPS Value Pathway (MVP) called Advancing Cancer Care. The Advancing Cancer Care MVP may appeal to some oncology practices that want to engage in care transformation but are wary about taking on downside risk with the EOM, as there is substantial overlap in the Advancing Cancer Care MVP improvement activities and the EOM participant redesign activities.
Since CMS hasn't yet released the full details of the EOM or the Advancing Cancer Care MVP, all panelists recommended that interested practices apply for EOM participation to buy time to thoroughly compare all three options.
3. The ability to invest in EOM care transformations will depend on market-level patient and payer dynamics
Under the EOM, providers will receive an extra $30 a month for treating dually-eligible beneficiaries, with that additional payment excluded from total cost of care responsibility. As one panelist pointed out, for practices that serve a high proportion of dually-eligible patients, this additional payment could go a long way toward investing in value-based care transformations without hurting providers' financial performance in the model, making it more favorable for these practices to participate in the EOM.
Similarly, practices should consider whether they can leverage their EOM participation with other payers in their markets through new payment arrangements or participation in existing commercial payer pilots with similar requirements.
These types of partnerships could allow practices to secure greater reimbursement for the care transformations they make and expand those services to all patients, making EOM participation more worthwhile for practices with a high proportion of patients with commercial insurance.
Through their experiences attempting to set up these agreements during the OCM, the panelists found that successfully creating these partnerships can depend on local market dynamics, including provider competition, current commercial oncology payment pilots, and administrative capacity among regional health plans.
4. Applying for EOM participation is not binding at this stage
Oncology physician group practices have until 11:59 PM on September 30, 2022 to apply to participate in the EOM through the EOM RFA Application Portal. CMS will notify applicants if they have been approved to participate in late winter 2022 or early spring 2023. However, approved applicants are not required to participate—they will still have to sign a participation agreement with CMS to confirm their participation.
Since the application is non-binding, all panelists recommended that interested practices apply, then use the fall and winter to further evaluate potential participation. This low-risk option buys time for practices to learn more about the financial benchmarks, quality measures, and reporting requirements and assess the potential costs and benefits of participating before deciding how to proceed.
This is important advice, as most practices will likely not know definitively if they want to participate before the September 30 deadline. Of 34 surveyed webinar attendees who are eligible for EOM participation, 25 (74%) said that they are "thinking about participating" but none reported they are "definitely participating". The other nine (26%) respondents had already ruled out participation.
With the deadline for submitting an EOM application approaching, oncology leaders should make sure they understand the model details available to date and engage their teams in discussions around what participation could mean for their practices.
Be sure to use our EOM readiness assessment to evaluate your readiness to participate in the model and view our relevant resources related to each requirement to help you prepare.