CMS' announcement of a new mandatory oncology bundled payment model wasn't a surprise. It reinforces CMS' continued commitment to creating innovative ways of transforming care.
This article has been written by Alyssa Dahl, MPH, CPH, manager of Healthcare Data Analytics at DataGen.
It’s always exciting to see new episodic bundling models being considered, as it’s indicative of the industry’s movement towards getting better value out of the healthcare system. It’s also a validation of all the work of early adopters of bundled payment models over the past 5 years. With last week’s announcement of a new oncology bundle, CMS is showing its continued commitment to creating innovative ways of transforming care.
CMS’ announcement wasn’t a surprise—the payer has been vocal that their work in oncology isn’t done yet. However, it has been heartening to see that despite political changes in the administration and the time taken to reevaluate these programs and how they’re being implemented, the play button for bundled payment models has been pressed again.
Here’s what we know so far:
This new bundle will be specific to patients undergoing radiation treatment. Patients being treated with radiation therapy alone are currently excluded from the Oncology Care Model (OCM), and patients who might be undergoing both chemotherapy and radiation can have periods of their cancer journey omitted from an OCM episode. Having a radiation oncology bundle will help oncology practices cover a larger pool of patients in a care transformation model. Radiation oncology episodes will also likely be shorter in duration than OCM episodes, to reflect the length of radiology treatment regimens and a period of monitoring for complications.
The 2 major unknowns:
1. A looming question is: will this bundle remain mandatory as stated by HHS Secretary Alex Azar? It’s an aggressive decision, since CMS hasn’t developed this kind of bundle before and doesn’t have the benefit of the experiences of participants in a voluntary version to build off of. There are a few radiation oncology bundles in the private sector that could dissuade CMS from making this model mandatory, but we will have to wait and see how those play out.
2. Questions remain around the alignment of this bundle with the current OCM. If the models run concurrently, some patients may fall into both an OCM and radiation oncology episode. CMS will need to determine how to calculate savings and how to allow for cross-participation across the 2 models. Episode attribution to either program will not be as simple as when the Comprehensive Care for Joint Replacement program was introduced while the original Bundled Payments for Care Improvement program was still running. For these 2 oncology bundles, there are many ways CMS could go.
Participants should stay tuned in to see if there’s anything in CMS’ rule-making that could possibly exclude their participation or impact their attributed OCM population. If there is, they may want to provide commentary to CMS to shape the future of both programs. Over the coming weeks we will be evaluating what can be modeled using the current and forthcoming program details and we encourage participants to be ready to have conversations around any new information we receive about this program in the coming weeks.