COA Submits OCM 2.0 Proposal

The Community Oncology Alliance (COA) has filed its alternative to CMS' Oncology Care Model (OCM) with the Physician-Focused Payment Model Technical Advisory Committee.

The Community Oncology Alliance has unveiled its long-awaited alternative to CMS’ Oncology Care Model (OCM). Dubbed OCM 2.0, the model aims to move toward higher quality, coordinated oncology care at equal to or lower cost.

Centered around standardized clinical improvements and baseline payment methodology criteria, OCM 2.0 will initially focus on Medicare patients and will incorporate 4 key features:

  • Serve as a flexible and adaptable universal payment reform template for all aspects of cancer care, regardless of payer
  • Recognize and reward high quality and value in cancer care
  • Promote simplicity in reporting requirements and transparency in the calculations that determine reimbursement
  • Address the price of cancer drugs by incorporating value-based initiatives to facilitate the correct care for each patient, while addressing disincentives for providing suboptimal care

“The proposal reflects a commitment to helping build the cancer care system of the future that patients, providers, and payers all want,” said Michael Diaz, MD, president of COA, and practicing medical oncologist at Florida Cancer Specialists & Research Institute, in a statement. “We urgently request that the committee take the recommendations of community oncology practices who are on the frontlines of treating this devastating disease and help us transform cancer care for generations to come.”

Based on feedback from practices participating in OCM and lessons learned from other alternative payment models (APMs), COA filed the plan with the Physician-Focused Payment Model Technical Advisory Committee, the federal agency that reviews physician-focused models for possible use by Medicare, after a year in development. With the publication of the proposal, a 3-week comment period has opened.

Scheduled to run through June 2021, the ongoing OCM includes 176 practices covering more than 150,000 Medicare beneficiaries. While practices have recognized the model as having helped them improve cancer care delivery, practices have also voiced concerns over shortcomings of and challenges with the model, including the reporting requirements and lack of transparency.

Results from performance period 3 (PP3), released in February, revealed no improvement over PP2. During both periods, just 30% of practices achieved shared savings, although the practices that shared savings differed between the 2 periods. With 2 years left of the model and no other proposed alternative, the question has remained as to what happens when the 5-year model comes to an end.

One of the other critiques of OCM is that is uses pricing models that were developed with claims data from 2012 to 2015, before the explosion of immuno-oncology drugs, and thus, even with the novel therapy adjustment and trend factor, the model is not relevant. Under OCM 2.0, the model would prioritize high-value treatment options like these, with incentives supported by current coverage guidelines and relevant diagnostics, according to COA.

In addition to improving upon the current model, OCM 2.0 will lead a path forward for a standardization of requirements set forth by APMs, according to COA, who identified 20 active APMs in the United States, all with a different set of standards and metrics. As for the payment methodology, the plan will use the standards of the Oncology Medical Home to ensure integrated and coordinated care.

During COA's 2019 Community Oncology Conference, Bo Gamble, COA’s director of strategic practice initiatives, explained that when developing OCM 2.0, the group worked directly with drug companies in order to gain an understanding of how value-based arrangements between drug companies and providers could be implemented successfully. As a result, the submitted proposal includes the promotion of these value-based arrangements, which can include those that guarantee specified tumor reduction or money back to the provider and/or patient, guaranteed reduction in the total cost of care for a time period as compared with standard of care, or guaranteed lowest cost per progression-free survival year.

“Implementation of this model will require a higher degree of collaboration, communication, and transparent than what has been demonstrated in the OCM,” wrote COA in the proposal. “Cancer care is complex and in a rapid and constant state of flux due to ever-increasing improvements in biotechnology and biopharmaceutical breakthroughs. It is understood and expected that adjustments will, of necessity, keep pace accordingly and dynamically through the life of this model.”

Understanding this need for flexibility, OCM 2.0 will include the ability to adjust the model components based on payer capabilities and the structural creation of options for providers to administer the requirements. According to COA, all revisions or improvements made to the model would be made by a small group of appointed decision makers, who would be recognized leaders of participating provider and payer groups.

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