UPDATE: CMMI Extends OCF Comment Deadline

Friday, Nov. 1 was a busy day for the Centers for Medicare & Medicaid Services (CMS) and its Center for the Medicare and Medicaid Innovation (CMMI). CMS released the final calendar year (CY) 2020 Hospital Outpatient Prospective System and Physician Fee Schedule final rules. Later that afternoon, CMMI posted an “informal” Request for Information on a proposal for the next iteration of an episode-of-care payment model for medical oncology, the Oncology Care First Model (OCF). CMMI unveiled this first look at a proposed successor to the Oncology Care Model (OCM), in advance of the planned Monday, Nov. 4 Public Listening Session to gather feedback on value-based payment to support high-quality oncology care. The CMMI OCF Request for Information states that: “We are currently anticipating that the OCF Model would be a voluntary, five-year model that would be tested throughout the United States from January 2021 to December 2025.” According to the Request for Information, the proposed OCF Model launch date of Jan. 2021 will not impact the current OCM as by that time, no new episodes of care will be initiating under the OCM.

Oncology Community Asks CMMI Extend the Comment Deadline & CMMI Agrees
During Monday’s Listening Session, the message from stakeholders was clear: CMMI, please extend the comment deadline for the RFI for the Oncology Care First Model. The Association of Cancer Care Centers (ACCC) joined in this request for more time to respond to the proposed model. Stakeholders agreed that announced comment deadline (15 business days from CMMI’s posting of the RFI) was not adequate to provide the quality input that CMMI is seeking on such critical issues as potential payment methodology, eligibility parameters, and downside risk.

UPDATE: On Friday, Nov. 8, CMMI announced an extension of the deadline for comments/feedback on the OCF Model in response to stakeholders' requests. CMMI has extended the feedback period until Friday, December 13, 2019. Written feedback can be sent to OCF@cms.hhs.gov, until the close of the feedback period. CMMI has also made a recording of the Nov. 4 Public Listening Session available. ACCC thanks CMMI for hearing stakeholders' requests and extending comment period deadline.

Outlining highlights of the OCF, Lara Strawbridge, Director of Ambulatory Payment Models at CMMI, described the OCF Model as “multi-payer” and a continuation of care transformation. “Patients are at the core of this model” which seeks better quality care for patients as costs are reduced, she said. In conceptualizing the OCF, Strawbridge said, the team at CMMI looked at “how can we push oncology practices beyond the incredible gains being made under the OCM.”

CMMI is specifically asking for input on:

• How the potential OCF model could build on lessons learned from the implementation of the practice redesign activities included in the Oncology Care Model (OCM)?
• What revisions or additions should be made to the OCM practice redesign activities in the potential model?
• The potential payment methodology under the potential model, including structure and design of the monthly population payment and performance-based payment (PBP).
• The possible inclusion of additional services in the monthly population payment, such as imaging or lab services.
• Feedback the conceptualized risk arrangements. CMMI seeks comments on how a downside risk arrangement might be best constructed in terms of level of risk?
• Comments from physician practice groups and hospital outpatient departments on their interest in participating in a potential Oncology Care First Model (OCF). CMMI wants feedback on the conceptualized participation eligibility parameters (e.g., the grouping concept). Will these parameters be feasible?

CMMI is also seeking feedback from potential payer partners, including commercial payers and state Medicaid agencies.

Last Friday in Orlando practice transformation, value-based oncology models, two-sided risk, and the potential next iteration of an oncology episode-of-care model was also under discussion at the ACCC Oncology Care Model Collaborative Workshop. ACCC hopes that the insights and perspectives still top-of-mind from Friday’s workshop will be beneficial to participants as they respond to CMMI’s serendipitous release of the OCF RFI.

ACCC will be providing comments to CMMI’s Request for Information on the potential Oncology Care First Model and encourages our membership to submit comments.

Updated 11/08/2019