Last month, the Centers for Medicare and Medicaid Services (CMS) released a Request for Information that positions the newly dubbed Oncology Care First (OCF) model as the evolution of the Oncology Care Model (OCM). The OCF, like the OCM, is voluntary and will involve an application process. It will likely begin sometime in the middle of next year.
It’s clear by now that CMS and their Innovation Center want to get providers comfortable with taking on financial risk, which they view as a means to control costs. Because of this, financial risk is a big component of the OCF. As proposed, if you are currently an OCM participant, you have to assume downside risk as part of OCF. If you were not an OCM participant, you can opt out of this downside risk for a limited time.
The intention of CMS to eventually move away from a fee-for-service model is pretty clear here, and to me the most striking element of the model is a new payment form called a Monthly Population Payment (MPP) with both an “Administration” and “Management” component. This essentially replaces E&M services and drug administration with a monthly payment (what is known as MEOS payments in the OCM). Here, CMS is also introducing three risk-stratified population payments by cancer type, where the payments would vary depending on your case mix. The OCF also has a retrospective Performance Based Payment (similar to the shared savings payment in the OCM today).
Where do drugs fit in? The RFI did not mention any change in drug reimbursement and we think they are likely to stay Medicare FFS. We’ll know more once the final details are released sometime next year.
Want to learn more? Join Basit Chaudhry, MD, PhD from Tuple Health and Ryan Holleran from Flatiron to learn about the proposed Oncology Care First model, what it means for your practice, and what to consider when applying.