CMMI’s New Enhancing Oncology Model – Deadline Approaching

As the final at-risk period for the Oncology Care Model was closing at the end of June, the Center for Medicare and Medicaid Innovation announced its new Enhancing Oncology Model (EOM). EOM aims to improve the coordination of oncology care, drive practice transformation and reduce Medicare fee-for-service spending through episode-based payment. 

What is EOM?

EOM is a voluntary, five-year model set to begin July 1, 2023. Patients undergoing chemotherapy for the treatment of cancer will trigger six-month episodes of care. 

Eligible EOM participants include physician group practices with at least one Medicare-enrolled physician or a non-physician practitioner who furnishes evaluation and management services to Medicare beneficiaries receiving chemotherapy for cancer treatment. 

EOM participants are required to implement eight participant redesign activities to drive care transformation in their practice. Examples include the provision of patient navigation, 24/7 access to an appropriate clinician for beneficiaries and implementation of health-related social needs screenings. 

Quality will be tied to payment in EOM with a combination of participant-reported, claims-based and patient experience survey measures. A limited set of clinical data elements not present in claims data will be collected semiannually. Participating practices will also be required to collect beneficiary-level sociodemographic data and establish a health equity plan to identify and address health disparities. 

Commercial payers, Medicare Advantage plans, and state Medicaid agencies are eligible to apply and partner with CMS for EOM to expand the reach of the model and achieve the goal of delivering high-value, patient-centered cancer care. 

How EOM differs from OCM

EOM will be limited to seven common cancer types: breast, prostate, lung, small intestine/colorectal, multiple myeloma, lymphoma and chronic leukemia. In OCM, providers were at risk for 21 different cancer types. Patients receiving hormonal therapies only will be excluded from the model. 

The EOM payment methodology will again include monthly enhanced oncology services payments to support care redesign activities; however, these will be paid at a lower rate than under OCM. The MEOS payment will be $70 per beneficiary per month during the six-month episode of care. An additional MEOS payment of $30 will be applied for the management of dual-eligible beneficiaries. 

EOM requires that participating practices take on immediate downside risk from the start of the model. Participants will have two risk arrangements to choose from, which differ in the EOM discount applied (i.e., 3% or 4% of the benchmark), stop-loss and stop-gain thresholds, and whether the arrangement qualifies as an advanced alternative payment model. Both risk arrangements include a neutral zone — a feature introduced late into OCM where an EOM participant does not earn a performance-based payment but also does not meet the threshold for recoupment. 

Despite many characteristics of the EOM target price methodology remaining similar to OCM, several key differences will prove beneficial for participants. The underlying baseline price prediction module now models prices separately for each of the seven cancer types. The impact of comorbidities is modeled with increased specificity, the experience adjustment will take into account practice and regional variability, and the trend factor and novel therapy adjustments have been made cancer-type specific. 

How should practices prepare for the Enhancing Oncology Model?

Physician group practices interested in EOM have until Sept. 30 to submit an application. Even if a practice is currently unsure about participating, applying opens the door for a practice to participate if accepted for the model but does not require the practice to move forward. Practices selected for the model will become participants when they sign their participation agreement. This allows practices to remain in consideration for the model and gives them time to evaluate any additional data that may become available. A participant can terminate participation with no risk, effective immediately, at any point prior to the model’s go-live date.