Oncology Care Model
FAQs and Applications
April 22, 2015
http://innovation.cms.gov/initiatives/
Oncology-Care/
OncologyCareModel@cms.hhs.gov
Oncology Care Model (OCM)
Overview
Practice Transformation
Physician practices that participate in OCM are required to
transform their practices to improve the quality of care they
deliver
Episode-Based
Total cost of care payment model initiates with chemotherapy
treatment and includes all medical services during the following 6
months
Multi-Payer Model
Medicare FFS and other payers work in tandem to support practice
transformation across the patient population
2
Practice Participants
3
Which practices can participate in OCM?
Eligible participants include:
• Physician group practices and solo practitioners that furnish
chemotherapy
• Multi-specialty practices
• Hospital*-owned practices and provider-based departments
• Practices that partner with hospital outpatient departments
for chemotherapy infusion services
*Hospital must be paid under
Medicare outpatient/inpatient
prospective payment system
4
Are there any practices that cannot
participate in OCM?
Not Eligible:
• PPS-exempt hospitals and affiliated practices
• Critical Access Hospitals (CAHs)
• Federally qualified Health Centers (FQHCs)
• Rural Health Clinics (RHCs)
• Maryland hospitals and physician practices
Due to the differences in their payment structures, entities that are not
paid off of Medicare’s OPPS/IPPS are not eligible to participate in OCM.
5
Must all sites of a multi-site practice
participate in the model?
Yes, all sites that bill under the applicant’s TIN
must participate.
If the practice wishes to include sites that bill
under a different TIN, those TINs need to submit
their own LOIs and applications.
6
What overlap is permissible between
OCM and other CMS programs?
Innovation Center Models
• Participation in certain shared savings programs and OCM is allowed
• Examples: Pioneer Accountable Care Organizations (ACOs), Medicare Shared
Savings Program (MSSP), Comprehensive Primary Care Initiative (CPC)
• Participation in Transforming Clinical Practice Initiative (TCPI) and OCM is not
allowed
Care Management Payments
• Chronic Care Management (CCM) and Transitional Care Management (TCM)
services: Practices that bill the OCM PBPM cannot also bill for CCM or TCM
services in the same month for the same beneficiary.
7
OCM Episodes
8
How is an episode of care triggered?
Episodes trigger with a Part B chemotherapy
administration claim or Part D chemotherapy claim and
an ICD-9 code for cancer.
• Inpatient chemotherapy will NOT initiate an OCM episode.
• Beneficiaries already receiving chemotherapy treatment when
OCM begins will be included in the model.
• Beneficiaries may initiate multiple episodes during the five-year
model performance period.
9
Will any services be excluded from
OCM episodes?
No. All Medicare Part A and B (and certain Part D)
expenditures will be included in the total cost of
care during OCM episodes.
• Examples include but are not limited to:
o Inpatient costs
o Post acute care services
o Drugs, labs, and imaging
o Surgery
o Radiation therapy
o Clinical trials
10
What cancer types will be included
in OCM?
OCM-FFS includes nearly all cancer types.
• Includes all cancer types treated with non-topical
chemotherapy
• Appendix D of the RFA lists all drugs that trigger an
OCM episode
Exclusions
• Cancer types treated exclusively with surgery,
radiation, or topical chemotherapy are excluded
11
Practice Requirements
12
When are practices required to meet the
six practice requirements?
Practices must meet the six practice requirements
by the end of the first quarter of the first
performance year.
(1) Provide 24/7 access to a clinician with patient’s medical
records
(2) Use ONC-certified EHR
(3) Use data for quality improvement
(4) Provide core functions of patient navigation
(5) Document IOM care plan
(6) Use therapies consistent with clinical guidelines
13
How often will practices be required to
report data to CMS?
Practices will report to CMS quarterly.
• To the extent possible, CMS will use existing data and
reporting systems to minimize the reporting burden on
practices
• CMS will issue quarterly feedback reports detailing
practices performance in OCM
14
OCM Payments
15
How will OCM payments be made?
Standard Medicare FFS payments will continue
during OCM episodes. In addition, OCM
incorporates two new model payments:
(1) Funding for enhanced care management services
• OCM provides $160 per-beneficiary-per-month payment for all
Medicare FFS beneficiaries in model
• Practices bill Medicare using a G-code created specifically for OCM
(2) Performance-based payment
• OCM provides semi-annual lump-sum performance-based payments
• OCM performance-based payments are determined by practices’
reductions in expenditures below a target price, and their performance
on quality measures
16
How are benchmarks calculated, and when
will practices know their benchmarks?
Benchmarking will be based on historical Medicare
expenditure data.
• Based on both practice data and regional/national data as
necessary to increase precision
• Risk adjusted, adjusted for geographic variation
• Trended to applicable performance period
• Trend factors will represent national trends in expenditures
CMS will make benchmark prices and other baseline data available
prior to practices signing participation agreements.
17
How will performance-based payments
be calculated?
1) CMS will calculate benchmark episode expenditures for participating
practices
• Based on historical data
• Risk-adjusted, adjusted for geographic variation
• Trended to the applicable performance period
2) A discount will be applied to the benchmark to determine a target price for
OCM-FFS episodes
• Example: Benchmark = $100  Discount = 4%  Target Price = $96
3) If actual OCM-FFS episode Medicare expenditures are below target price, the
practice could receive a performance-based payment
• Example: Actual = $90  Performance-based payment up to $6
4) The amount of the performance-based payment may be reduced based on the
participant’s achievement and improvement on a range of quality measures
18
How will CMS account for the cost of new
technologies?
CMS is aware of the significant clinical and cost
implications of novel breakthrough therapies.
• We do not wish to penalize practitioners for providing
state-of-the-art care.
• Specific methodologies to account for new technologies
in OCM episode pricing will be available prior to
practices signing agreements.
19
What risk arrangements are offered
in OCM?
One-sided risk
• All model participants in Years 1 and 2
• Participants are NOT responsible for Medicare expenditures that
exceed target price
• Medicare discount = 4%
Two-sided risk
• Model participants can elect two-sided risk beginning in Year 3
• Participants are responsible for Medicare expenditure that exceed
target price
• Medicare discount = 2.75%
All practices must qualify for performance-based payment by end of Year 3.
20
Application and Payer Participation
21
How will practices know what payers may
participate in OCM?
The list of payers who submitted LOIs and agreed
to public posting is currently available on the OCM
website.
• 48 payers submitted LOIs
• Considerable geographic diversity among payers
• Payers are including many different lines of business
CMS strongly encourages practices and payers to communicate during
the OCM application period and coordinate their OCM participation.
22
Where are potential OCM payers located?
23
Is applying with other payers a
requirement for practices?
No, but it is strongly encouraged.
• Participating in OCM with multiple payers allows for
broader practice-level support for transformation.
– Accordingly, participation with other payers is worth 30
(of total 100) application points.
• Practice applications must include a letter of support
from each partnering payer.
24
Must applicants submit LOIs in order to
apply for OCM?
Yes. Payers and practices who wish to apply for participation in
OCM must first submit a non-binding LOI.
Payer LOI Deadline: 5:00pm EDT on April 9, 2015
Payers who agreed to public posting are listed on OCM website now
Practice LOI Deadline: 5:00pm EDT on May 7, 2015
Practices agreeing to public posting will be listed on OCM website on 5/14
LOI forms are available for download on the OCM website and should be
submitted by email to the OCM inbox: OncologyCareModel@cms.hhs.gov
25
How do payers and practices
access the web-based application?
ALL applications are due by 5:00 pm EDT on June 18, 2015
• Applications must be completed online using an authenticated web link
and password, which will be emailed to POCs listed on LOIs
Notify CMS at OncologyCareModel@cms.hhs.gov if your POC changes prior to
receiving the application link
• Application templates are available on the OCM website
For reference only – CMS will not accept these templates for application
submission
• Payers and practices apply separately
Practices must submit letters of support from payers with whom they wish to
participate in OCM, and payers must list practices with whom they wish to
participate
26
Sample OCM Practice Application
27
Care Settings
28
Alternative Billing Arrangements
29
E & M Billing
30
Pooling
31
Practice Revenue
32
Implementation Information
33
Narrative Attachments
34
How will practice applications be scored
and selected?
Implementation Plan (40 points)
Full description of the practice’s plan for the first 2 OCM performance years,
including current and proposed implementation of practice requirements,
Financial Plan (25 points)
Full description of the practice’s financial plan to support the
implementation plan for the first 2 OCM performance year years, including
use of PBPM payments, expected performance-based payments, and
expected payments from other payers
Participation with Other Payers (30 points)
Letters or explanations of support from payers with which practice wishes to
participate in OCM
Diverse Populations (5 points)
Practice’s plan to treat and engage diverse and/or underserved populations
(including dual eligible beneficiaries) during OCM
35
When will practices be notified of their
selection to participate in OCM?
CMS will notify practices of their selection to
participate in OCM in late 2015 / early 2016
• Practices will sign participant agreements with the CMS
Innovation Center
• Agreements will include details on benchmarking
methodology, quality scoring methodology, and reporting
requirements
36
Contact Information
CMMI Oncology Care Model
OncologyCareModel@cms.hhs.gov
http://innovation.cms.gov/initiatives/Oncology-Care/
37

Webinar: Oncology Care Model - Frequently Asked Questions and Application Overview

  • 1.
    Oncology Care Model FAQsand Applications April 22, 2015 http://innovation.cms.gov/initiatives/ Oncology-Care/ [email protected]
  • 2.
    Oncology Care Model(OCM) Overview Practice Transformation Physician practices that participate in OCM are required to transform their practices to improve the quality of care they deliver Episode-Based Total cost of care payment model initiates with chemotherapy treatment and includes all medical services during the following 6 months Multi-Payer Model Medicare FFS and other payers work in tandem to support practice transformation across the patient population 2
  • 3.
  • 4.
    Which practices canparticipate in OCM? Eligible participants include: • Physician group practices and solo practitioners that furnish chemotherapy • Multi-specialty practices • Hospital*-owned practices and provider-based departments • Practices that partner with hospital outpatient departments for chemotherapy infusion services *Hospital must be paid under Medicare outpatient/inpatient prospective payment system 4
  • 5.
    Are there anypractices that cannot participate in OCM? Not Eligible: • PPS-exempt hospitals and affiliated practices • Critical Access Hospitals (CAHs) • Federally qualified Health Centers (FQHCs) • Rural Health Clinics (RHCs) • Maryland hospitals and physician practices Due to the differences in their payment structures, entities that are not paid off of Medicare’s OPPS/IPPS are not eligible to participate in OCM. 5
  • 6.
    Must all sitesof a multi-site practice participate in the model? Yes, all sites that bill under the applicant’s TIN must participate. If the practice wishes to include sites that bill under a different TIN, those TINs need to submit their own LOIs and applications. 6
  • 7.
    What overlap ispermissible between OCM and other CMS programs? Innovation Center Models • Participation in certain shared savings programs and OCM is allowed • Examples: Pioneer Accountable Care Organizations (ACOs), Medicare Shared Savings Program (MSSP), Comprehensive Primary Care Initiative (CPC) • Participation in Transforming Clinical Practice Initiative (TCPI) and OCM is not allowed Care Management Payments • Chronic Care Management (CCM) and Transitional Care Management (TCM) services: Practices that bill the OCM PBPM cannot also bill for CCM or TCM services in the same month for the same beneficiary. 7
  • 8.
  • 9.
    How is anepisode of care triggered? Episodes trigger with a Part B chemotherapy administration claim or Part D chemotherapy claim and an ICD-9 code for cancer. • Inpatient chemotherapy will NOT initiate an OCM episode. • Beneficiaries already receiving chemotherapy treatment when OCM begins will be included in the model. • Beneficiaries may initiate multiple episodes during the five-year model performance period. 9
  • 10.
    Will any servicesbe excluded from OCM episodes? No. All Medicare Part A and B (and certain Part D) expenditures will be included in the total cost of care during OCM episodes. • Examples include but are not limited to: o Inpatient costs o Post acute care services o Drugs, labs, and imaging o Surgery o Radiation therapy o Clinical trials 10
  • 11.
    What cancer typeswill be included in OCM? OCM-FFS includes nearly all cancer types. • Includes all cancer types treated with non-topical chemotherapy • Appendix D of the RFA lists all drugs that trigger an OCM episode Exclusions • Cancer types treated exclusively with surgery, radiation, or topical chemotherapy are excluded 11
  • 12.
  • 13.
    When are practicesrequired to meet the six practice requirements? Practices must meet the six practice requirements by the end of the first quarter of the first performance year. (1) Provide 24/7 access to a clinician with patient’s medical records (2) Use ONC-certified EHR (3) Use data for quality improvement (4) Provide core functions of patient navigation (5) Document IOM care plan (6) Use therapies consistent with clinical guidelines 13
  • 14.
    How often willpractices be required to report data to CMS? Practices will report to CMS quarterly. • To the extent possible, CMS will use existing data and reporting systems to minimize the reporting burden on practices • CMS will issue quarterly feedback reports detailing practices performance in OCM 14
  • 15.
  • 16.
    How will OCMpayments be made? Standard Medicare FFS payments will continue during OCM episodes. In addition, OCM incorporates two new model payments: (1) Funding for enhanced care management services • OCM provides $160 per-beneficiary-per-month payment for all Medicare FFS beneficiaries in model • Practices bill Medicare using a G-code created specifically for OCM (2) Performance-based payment • OCM provides semi-annual lump-sum performance-based payments • OCM performance-based payments are determined by practices’ reductions in expenditures below a target price, and their performance on quality measures 16
  • 17.
    How are benchmarkscalculated, and when will practices know their benchmarks? Benchmarking will be based on historical Medicare expenditure data. • Based on both practice data and regional/national data as necessary to increase precision • Risk adjusted, adjusted for geographic variation • Trended to applicable performance period • Trend factors will represent national trends in expenditures CMS will make benchmark prices and other baseline data available prior to practices signing participation agreements. 17
  • 18.
    How will performance-basedpayments be calculated? 1) CMS will calculate benchmark episode expenditures for participating practices • Based on historical data • Risk-adjusted, adjusted for geographic variation • Trended to the applicable performance period 2) A discount will be applied to the benchmark to determine a target price for OCM-FFS episodes • Example: Benchmark = $100  Discount = 4%  Target Price = $96 3) If actual OCM-FFS episode Medicare expenditures are below target price, the practice could receive a performance-based payment • Example: Actual = $90  Performance-based payment up to $6 4) The amount of the performance-based payment may be reduced based on the participant’s achievement and improvement on a range of quality measures 18
  • 19.
    How will CMSaccount for the cost of new technologies? CMS is aware of the significant clinical and cost implications of novel breakthrough therapies. • We do not wish to penalize practitioners for providing state-of-the-art care. • Specific methodologies to account for new technologies in OCM episode pricing will be available prior to practices signing agreements. 19
  • 20.
    What risk arrangementsare offered in OCM? One-sided risk • All model participants in Years 1 and 2 • Participants are NOT responsible for Medicare expenditures that exceed target price • Medicare discount = 4% Two-sided risk • Model participants can elect two-sided risk beginning in Year 3 • Participants are responsible for Medicare expenditure that exceed target price • Medicare discount = 2.75% All practices must qualify for performance-based payment by end of Year 3. 20
  • 21.
    Application and PayerParticipation 21
  • 22.
    How will practicesknow what payers may participate in OCM? The list of payers who submitted LOIs and agreed to public posting is currently available on the OCM website. • 48 payers submitted LOIs • Considerable geographic diversity among payers • Payers are including many different lines of business CMS strongly encourages practices and payers to communicate during the OCM application period and coordinate their OCM participation. 22
  • 23.
    Where are potentialOCM payers located? 23
  • 24.
    Is applying withother payers a requirement for practices? No, but it is strongly encouraged. • Participating in OCM with multiple payers allows for broader practice-level support for transformation. – Accordingly, participation with other payers is worth 30 (of total 100) application points. • Practice applications must include a letter of support from each partnering payer. 24
  • 25.
    Must applicants submitLOIs in order to apply for OCM? Yes. Payers and practices who wish to apply for participation in OCM must first submit a non-binding LOI. Payer LOI Deadline: 5:00pm EDT on April 9, 2015 Payers who agreed to public posting are listed on OCM website now Practice LOI Deadline: 5:00pm EDT on May 7, 2015 Practices agreeing to public posting will be listed on OCM website on 5/14 LOI forms are available for download on the OCM website and should be submitted by email to the OCM inbox: [email protected] 25
  • 26.
    How do payersand practices access the web-based application? ALL applications are due by 5:00 pm EDT on June 18, 2015 • Applications must be completed online using an authenticated web link and password, which will be emailed to POCs listed on LOIs Notify CMS at [email protected] if your POC changes prior to receiving the application link • Application templates are available on the OCM website For reference only – CMS will not accept these templates for application submission • Payers and practices apply separately Practices must submit letters of support from payers with whom they wish to participate in OCM, and payers must list practices with whom they wish to participate 26
  • 27.
    Sample OCM PracticeApplication 27
  • 28.
  • 29.
  • 30.
    E & MBilling 30
  • 31.
  • 32.
  • 33.
  • 34.
  • 35.
    How will practiceapplications be scored and selected? Implementation Plan (40 points) Full description of the practice’s plan for the first 2 OCM performance years, including current and proposed implementation of practice requirements, Financial Plan (25 points) Full description of the practice’s financial plan to support the implementation plan for the first 2 OCM performance year years, including use of PBPM payments, expected performance-based payments, and expected payments from other payers Participation with Other Payers (30 points) Letters or explanations of support from payers with which practice wishes to participate in OCM Diverse Populations (5 points) Practice’s plan to treat and engage diverse and/or underserved populations (including dual eligible beneficiaries) during OCM 35
  • 36.
    When will practicesbe notified of their selection to participate in OCM? CMS will notify practices of their selection to participate in OCM in late 2015 / early 2016 • Practices will sign participant agreements with the CMS Innovation Center • Agreements will include details on benchmarking methodology, quality scoring methodology, and reporting requirements 36
  • 37.
    Contact Information CMMI OncologyCare Model [email protected] http://innovation.cms.gov/initiatives/Oncology-Care/ 37