The following is a guest blog post by Dr. Charles Saunders, CEO, Integra Connect.
The Oncology Care Model (OCM) – an alternative payment model introduced in July 2016 by the Center for Medicare and Medicaid Innovation – launched with the ambitious goal to further delivery of higher quality, more coordinated cancer care at a lower cost. Participants include 184 practices representing approximately one-third of community oncologists in the US. They receive a so-called “MEOS” (monthly enhanced oncology services) payment of $160 per beneficiary per month for the duration of a qualifying 6-month chemotherapy period, plus the opportunity to earn a share of savings if they exceed a target threshold. In return, oncologists are expected to take on increasing accountability for patient outcomes and well-being, while also generating sustainable cost savings across all co-morbidities and care settings, into the patient home.
OCM Performance Period 1 Results Exposed an Unexpected Misalignment
As part of the OCM program, CMS tracks practices during 6-month intervals – so-called “performance periods” – then shares results back about one year later. In February 2018, practices participating in the OCM program received visibility into Performance Period 1 (PP1) data, including savings achieved, aggregate quality score, and effectiveness of identifying eligible patients. While most practices were unsurprised by their performance scores, many did not anticipate the extent to which CMS would recoup MEOS payments that it deemed paid in error. The most common scenario involved patients with co-morbidities who, while receiving chemotherapy and related services, also visited other providers regularly. Therefore, the oncology practice did not represent the required plurality of E/M codes for that beneficiary. It was not uncommon for practices to be asked to return up to 30% of the sum they had been paid – a major financial hit.
Lack of Data Hinders Practices’ Ability to Accurately and Proactively Identify Beneficiaries
In May 2018, practices received their Performance Period 2 (PP2) Attribution Lists, which summarized which CMS beneficiaries met OCM eligibility criteria, which episodes were attributed to each respective practice, and episode start dates from January 1, 2017 through June 30, 2017. Unfortunately, because there is a significant lag between actual Performance Period and delivery of CMS findings – delayed up to nearly a year after each performance period has ended – OCM participants were unable to retroactively apply PP1 learnings to PP2.
Why is this especially problematic? Practices are faced not only with MEOS recoupments for erroneous payments but, with only a 1-year window to submit claims, are often unable to bill in full for patients who were missed. Indeed, there are many opportunities to miss appropriate patients, as practices needed to have an accurate view of: 1) all beneficiaries; 2) those with a qualifying diagnosis; 3) those with a new chemo episode; 4) those not only prescribed an oral agent, but those who subsequently filled it; 5) those not in a hospice; and more. Given all the dimensions to track and measure, practices without advanced tools face delivering enhanced services that they cannot correctly bill for.
Best Practices from Community-Based Oncology Practices Include Robust Data
What best practices arose to get attribution right? A vanguard of OCM practices realized that they would need to take proactive steps to enable near real-time visibility into their patient populations, embracing the tenets of population health management. Below is an example of the best practices adopted by several of these community-based oncology practices:
- Increased transparency into oral chemotherapies: Existing practice protocols did not open an episode when oral agents were prescribed, since there was no in-office administration. To address this, the practice introduced a rule-based algorithm to identify all OCM eligible patients, including those who had been prescribed orals. In addition, they enlisted a combination of automated and personal follow-ups to validate qualification and ensure orals had been filled.
- Avoidance of duplication: To identify missed billing opportunities while also reducing the risk of duplicated claims, practice leadership invested in a robust analytics tool that enabled personalized queries at the patient level. These reports compared eligibility against their practice management report to identify gaps, from unpaid and unbilled to denied.
- Targeted patient intervention: To balance the practice’s financial and clinical objectives while optimizing OCM performance, the practice introduced complex care management services and employed a series of triage pathways. This approach ensured engagement with attributed beneficiaries and decreased avoidable high-cost events among at-risk patients, such as inappropriate ER visits and inpatient stays.
- Optimized treatment choices. As part of its commitment to ensure each patient received the most effective treatment for his or her disease, the practice provided increased transparency around the availability of equally effective generic or biosimilar drugs. They also supported better end-of-life planning for patients facing second or third-line therapies not expected to provide any clinical benefits, but that could significantly degrade remaining quality of life.
- Continuous performance improvement: To track the effectiveness of these quality improvement initiatives, the practice leveraged its analytics tool to monitor resource utilization and care management performance, then intervened to address outliers in real-time.
In short, to optimize performance under the OCM, practices are beginning to leverage the data to which they already have access – both clinical and financial – to risk-stratify their patient populations; identify OCM eligible patients; and gain near real-time visibility into quality and cost performance. Practices are also investing in better data integration and analytics that enable rules-based identification of eligible patients.
Population Health Analytics Help Practices Be Proactive and Succeed Under the OCM
Oncology is on the forefront of value-based care adoption and these early experiences from the OCM have provided a guide for other specialties. Based on their early results, what has come to the forefront is the need for a combination of comprehensive data management and robust analytics, coupled with the principles of population health management, which enable practices to step up and take control of the cost and quality for their attributed populations.