The Enhancing Oncology Model: Stakeholder Perspectives on EOM Prelaunch
Ron Barkley, MS, JD, from the Cancer Center Business Development Group, speaks with Marissa Rivera, MBA, Ventura County Hematology Oncology Specialists; Alexandra Chong, PhD, Center for Medicare & Medicaid Innovation; Barry Russo, MBA, The Center for Cancer and Blood Disorders; and Eileen Witherspoon, MPH, Center for Medicare & Medicaid Innovation, about the launch of the Enhancing Oncology Model.
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Read the full transcript:
Ron Barkley, MS, JD: Welcome to the Cancer Care Business Breakthroughs, a video series in which we host conversations around cutting-edge topics, innovations, and disruptions in the business of cancer care and their implications for community oncology.
I'm Ron Barkley. I'm a principal in the Cancer Care Business Exchange, a thought leadership forum focused on matters of business and finance in cancer care.
In today's edition of our Business Breakthroughs video series, we'll be hearing about the enhancing oncology model (EOM) from the perspective of EOM leadership at the Center for Medicare and Medicaid Innovation and from the perspective of participants in the EOM program.
Today's panelists are Alexandra Chong, the EOM Policy team lead at CMMI; Eileen Witherspoon, the EOM Operations team lead at CMMI; Barry Russo, CEO of The Center for Cancer and Blood Disorders in Fort Worth; and Marissa Rivera, Chief Financial Administrative Officer, Ventura County Hematology Oncology Specialists.
Before we get started with our discussion, allow me to highlight the salient features of the EOM program. EOM is essentially the successor program to CMMI's Oncology Care Model, the OCM model, that was conducted over a 6-year time frame commencing July 2016, and, of note, both of our practices today are participants in the EOM program, also participated in the OCM program.
The new EOM program commences about a month from now, July 1. EOM includes Medicare beneficiaries that are receiving systemic chemotherapy for seven specifically identified cancer types. EOM participants take on the accountability for their Medicare patients’ health quality and total spend, during a 6-month episode of care. Participants can bill a monthly enhanced oncology services payment, referred to as a MEOS, for providing enhanced services to the eligible Medicare beneficiaries. Although the MEOS payment in EOM is less than the MEOS payment that was paid under the OCM program.
And finally, and probably most noteworthy, is that the EOM program commences with two-sided risk; two-sided risk is mandated. Participants in the EOM can earn a retrospective, performance-based payment (PBP), based on quality and savings achieved. However, the participants are also subject to a performance-based recoupment should saving targets not be achieved. This upfront two-sided risk feature is unlike OCM, where the assumption of downside financial risk was optional up until the eighth performance period of the OCM program. So, that is the background.
Let me turn to Alexandra Chong for her insights regarding CMMI's expectation of EOM. And Alex, what does CMMI expect to gain from the EOM program, and what, if any, challenges do you see with the program?
Alexandra Chong, PhD: Yeah, thanks so much, Ron, and thank you so much for this invitation to speak on EOM. That was really nice background and history on OCM as the predecessor model, and also great updates on the current standing for EOM.
So, to answer your first question in terms of what does CMS expect to gain from the EOM program, I would say that we have three general goals that we are expecting and hoping to meet as a result of EOM.
The first goal that we have is to align with or meet the goals of the CMMI strategic refresh.
Before we announced the model itself, which was actually coming up here on our one-year anniversary, so it was around June of 2022 last year, CMS also released information in regards to the strategic refresh and the general pillars in which the models out of CMMI would align to.
For EOM, we expect to gain from the model test itself that we see a lot of alignment across three pillars. The first is on accountability. So, accountability speaks to an expectation that all Medicare beneficiaries are in a care relationship with accountability for quality and total cost of care. And so just noting that because EOM is a total cost of care model with a payment structure that is dependent on quality performance, we see this model aligning nicely within that pillar.
We also see that within EOM, there's going to be a pursuit of strategies to address different health care prices, affordability, and to reduce waste. That speaks to the affordability pillar of the strategic refresh. We've gotten a lot of questions about this for EOM, but we continue to stand by our decision in, you know, including drugs, and also again having the inclusion of those expenditures as a total cost of care model with that downsided risk requirement because we want to continue to keep that downward pressure on drugs.
We want to continue things like encouraging high-value drug prescribing. We saw through OCM that this behavior was really increasing throughout the test of OCM and are really encouraged about that. And with this, you know, I think this takes into consideration the beneficiary cost sharing and liability aspects as well. I think it speaks to affordability both for CMS as a Medicare payer and for beneficiaries. So, for instance, part of our model design, and those of you in OCM are familiar with this as well, is in EOM we require discussion on out-of-pocket cost for treatment, and this really brings to light providers on the cost implications and issues surrounding financial toxicity.
And then, finally, another main pillar of the strategic refresh that we hope to gain more insight from and align with, of course, is health equity. Health equity speaks to the public commitment in embedding equity into every aspect of the CMMI models, and also to reach vulnerable populations and achieve better outcomes.
We have all these goals within EOM as well. There are vast disparities that exist within cancer care. And we have very specifically designed our health equity strategy in a way to address those disparities. We want to ensure that model requirements really take into consideration these disparities, think strategically on the data that they have across different populations within their community.
I would also say here that our second goal, of course, is that EOM has been aligned with the Biden Administration's Cancer Moonshot. And the particular pillar within the Cancer Moonshot, which is somewhat related, but still different from the CMMI strategic refresh is supporting patients and caregivers. And so, part of that pillar is to improve the experience of people and their families living with and surviving with cancer.
For EOM, we see this as a model that advances full-person care and really incentivizes providers to tailor each unique patient, and treat the whole person, not just the disease. So, this model is designed to identify and address health-related social needs and also support providers to care for underserved communities. So, a little bit of crossover there with the health equity strategy as well.
And then, finally, the third thing that we hope to achieve from this model is really kind of shifting away from traditional Medicare fee for service. We at CMS have often been asked in terms of, you know, not only what do we have to gain from EOM but why, you know, why will we encourage participation within EOM?
I think one thing to note about this, and this is really a goal across the Innovation Center, is the current state of Medicare fee for service is likely not going to last in the long term. Like, when you're looking, you know, 50 years from now, 100 years from now, a fee-for-service system is not sustainable, especially within the oncology space. So, we really see EOM as an opportunity to shift away from that fee for service, which leads to unnecessary waste, and test the waters in a supported environment in value-based care. So, those are the three areas of just what our goals are for EOM, what we hope to achieve in terms of meeting those goals.
I want to address the second part of your question is, what challenges do we anticipate with a launch of EOM. I would say, in terms of like with any model test, of course it is going to come with challenges, both on the side of participants who are, you know, participating in the model and implementing the model, but also on the side of CMS. And if I were to describe what these challenges are in a collective theme, I would describe it as a challenge in terms of really trying to meet the needs of a delicate balance. So, balance is definitely where we see challenges happening here.
One area that we see balance happening, maybe more so on the participant front, and this is something that, you know, we'll certainly learn from together as the model starts, is balancing a need for the MEOS payments, the monthly enhanced oncology service payment, that's intended to support the enhanced services and EOM. But again, I think, balancing that with the total cost of care and downsided risk structure in our payment mechanism. We know that practices from OCM really rely heavily on the MEOS payments to support those enhanced services, and we also acknowledge that there are some new enhanced services in comparison to OCM.
And, as you mentioned before, Ron, our MEOS payment is slightly lower than what we had in OCM. And so I think we've heard from a lot of different practices on different strategies, on balancing that need like, how do you bill for the MEOS payment when that is a payment that's needed to support the infrastructure and the resources that are needed, for, you know, model implementation, while at the same time acknowledging that that is included, or the base amount at least, in EOM is included as part of the total cost of care responsibility. And you're also in a downsided risk arrangement where you're financially liable for your expenditures. So, I think kind of overseeing how practices navigate a good balance in that is something that we're going to want to observe.
I would also say that we are looking into balancing just the different needs of practices and the best strategies to support practices based on such a wide range of different characteristics. So, very similar to OCM, our process characteristics for EOM participants is really heterogeneous. So, it ranges from things like one of the largest health systems across the United States all the way to, you know, maybe just a single provider in a rural area. So, there's a lot of different characteristics there and what infrastructure is needed to support the implementation of the model.
But in EOM we're now dealing with practices, with that same wide range and diversity of practice characteristics, but now also with some prior OCM experience and some participants with no OCM experience, and quite possibly, maybe not a lot of experience in delving into value-based care as well.
And then finally, in terms of another sort of balance that we are trying to navigate, is just streamlining center-wide efforts across multiple models. We understand that EOM participants are also engaged in other initiatives and models, that EOM is not the only model that they may be participating in through the Innovation Center, or even through like their quality-based initiatives through their practice. So, I think just kind of streamlining a lot of things, for instance, health equity requirements, data sharing, quality measure reporting, balancing kind of the intention on wanting to streamline those efforts across multiple initiatives, but also taking into account that when we require these aspects of a model test that at times it can be very unique within an oncology space and oncology community.
Barkley: Thank you very much for those insights. And I know you had a leadership role in OCM, so congratulations to the EOM program that you're going to be able to bring those lessons learned in that experience to the new program. I'm curious about the program's assumption of risk, that is, you know, the participants are subject to downside risk if certain financial targets aren't achieved.
And so why did CMMI feel it important that participants assume risk in the model? And do you think that that mandatory risk feature might result in a smaller number of participants in EOM than you experienced in OCM?
Dr Chong: Yeah, thank you, Ron, I think this is such a great question, and such an important question to address for EOM. I would start off by saying a primary reason that drives so much of our financial methodology and our policy when we develop our model tests is just taking into consideration what our statutory requirements are across all of our models that come out of CMMI.
So, within our statutory requirements, which many of you may have already heard before, is our goal here is to improve quality and reduce cost. And so, when we design these models, EOM included, we're intending it to meet one of three potential scenarios. So, the first scenario is to reduce costs within a model test, but perhaps quality is maintained as neutral. So, there isn't a declining quality. The second scenario is that we improve quality, but then the costs remain neutral. And then finally, in the third scenario, which is the ideal scenario, is to both simultaneously improve quality and also reduce costs.
So, learning from OCM, the predecessor model to EOM, that downsided risk requirement was really carefully developed with our Office of Actuary in order for CMMI to be able to run a voluntary model test while achieving savings in the oncology space. Again, I would also remind folks just about our intentions on meeting the goals of the CMMI refresh, particularly within the pillars of accountability and affordability.
Having a total cost of care model and having that total cost of care model be implemented in a way in which downsided risk was required, was something that was very intentional. We want to continue to hold oncologists and providers accountable to provide quality care that takes into consideration high-value care. And so, we saw that as necessary to require a downsided risk requirement, in which providers are responsible for all the cost of their patients.
This helps to drive and address their coordination, thinking about care for their patient from a whole-person perspective, thinking about their patients not just in these short increments of patient time, but really through the entirety of the duration of their treatment journey.
And then, again, I mentioned earlier this too, is really that downsided risk requirement was to address affordability, not just affordability, you know, on Medicare as a payer but met affordability for the beneficiaries as well.
To get at your second question within your comment here on our participation, and what we expect for participation, particularly in light of OCM. While right now we can't specify about exact participation in numbers in EOM yet, we can signal that we are really encouraged by the participation that we are seeing. One thing to keep in mind when we think about this participation as well is just again, as the predecessor model in OCM, just noting that not all participants were in a downsided risk arrangement, and things, I think, got pretty complex particularly towards the end of the model, especially with our allowance to forego risk for the remainder of the model due to COVID flexibility.
So, when you think about the participation in OCM and the number of practices who retained a downsided risk arrangement, or took on a downsided risk arrangement, throughout the public health emergency, and examining our current participants in EOM, we are extremely pleased about those willing to take this next step with us in value-based care.
Barkley: Thanks so much, Alex, for those insights. Eileen, let's shift to you. You're tasked with the responsibility for the overall operations of EOM. So, my question would be: As you get close to the program, go-live in about a month, provide us with some insights on the tasks that are involved in the operations to prepare for the program launch and maybe describe your biggest challenges?
Eileen Witherspoon, MPH: Thanks, Ron, and also wanted to echo Alex; thank you for having us on here today. So, I did want to start with two of our teams' main tasks, which have been the development of the participation agreement and also the HIPAA-covered data disclosure request and attestation, or DIR-A form. We have worked closely with our legal counsel to make those documents available as soon as possible to potential participants. And, to provide some transparency, the clearance of these documents is a lengthy and complex process, with coordination from multiple groups and multiple layers of consensus needed before the documents can be finalized.
We also worked as quickly as possible to share historical data. We have to ensure there are protections and safeguards in place for all parties in the contract. We also have been working with multiple contractors supporting this effort, including setting up the platform and other data infrastructure considerations. We had to balance timely creation of the data sharing platform while also focusing on improvement to the usability of the data for participants, which was based on feedback shared from past model experience.
I did want to highlight two data-sharing improvements in EOM: that claims data will be shared monthly, and the data will also be available via an interactive dashboard to make the data more usable for practices. I did want to highlight in OCM data was shared by CCW [Chronic Conditions Data Warehouse], which was set up for research purposes.
We also must ensure EOM data sharing is done within the scope of regulations for HIPAA-protected beneficiary identifiable data in terms of what we can share and how we can share it. Additionally, we have been mindful of the differing data-reporting capabilities of EOM participants, and that some may have more advanced options available. So, we are increasing our interoperability standards to incorporate the use of the FHIR API standard and the use of mCODE, again meeting multiple groups' expertise to make both of these standards available for data reporting while also providing low-tech options for practices that may not have these capabilities.
We have also been working tirelessly to ensure successful model launch on July 1. And I did want to highlight three key areas that we've been working on. So, in terms of data, the portals are up and running for data sharing and future data reporting. Historical data was recently released to practices that had signed both the participation agreement and DIR-A. The historical data can help participants learn about their patient population, gain insight into total cost of care for attributed episodes, and calculate predicted expenditures for attributed episodes using the price prediction model coefficients.
In terms of payment, guidance will be provided for the monthly enhanced oncology services, or MEOS, payments, so that participants will know in advance how to bill if they so choose to do that. Just as a reminder, that's a $70 per-beneficiary per-month base payment. And then there's an additional $30 payment for dually eligible beneficiaries that is not part of the total cost of care responsibility.
Billing guidance will also be provided for benefit enhancements for those who have chosen to provide one or both optional benefit enhancements, which are the post-discharge home visits and care management home visits. We're also planning to release an updated payment methodology document, which provides additional information on both MEOS and EOM's retrospective reconciliation methodology.
In terms of quality, we want to ensure high quality patient-centered care is provided by EOM participants. Our quality strategy includes quality measures and data reporting; care transformation through participant redesign activities; and advancing health equity through incentivizing care for underserved beneficiaries and collecting beneficiary-level sociodemographic data from participants. Additionally, participants will identify health-related social needs, improve shared decision-making and care planning, and also develop health equity plans as part of continuous quality improvement. I did want to highlight, too, that we're engaging with other payers to support practice transformation for participants through multipayer alignment; that's part of EOM.
And then, finally, I did just want to highlight some additional resources that are available to support participants, including FAQs that are regularly updated; an onboarding guide that will be released prior to model start, in addition to numerous guides that have already been released; we have a robust help desk support in place; we have an EOM website and a connect portal with resources; an e-newsletter will be coming out shortly; there are project officers that are model team members assigned to each participant for additional support; and we have webinars on specific areas of interest, including, we have one on the participation agreement, payment, and quality measures to name a few.
So, the model team is ready to support EOM participants and EOM payers, and we're excited for EOM to launch on July 1.
Barkley: Terrific, thank you. You got your hands full! Now, let's you hear a little bit from your customers, some EOM participants. First up, The Center for Cancer and Blood Disorders, which is a relatively large-size, 36-physician community oncology practice in Fort Worth.
Barry, I'll turn to you. Your practice was an active participant in the OCM model. So, a couple of questions: What were your main takeaways from OCM that informed you about your decision to participate in EOM? And, more specifically, what kind of process did your practice go through in determining to participate in EOM?
Barry Russo, MBA: No, I appreciate it, Ron. Thanks for having me, and thanks for letting us have a voice in the process to the CMS folks as well; we appreciate that. Yeah, we were in OCM from the beginning all the way through the pandemic until the end, right? And so, we learned a lot through the process. We really did. We learned a lot about the challenges of coordination of care and of population health in the oncology world and how complicated that can be.
We learned a lot about situations where we could have and did have outlier scenarios, totally unexpected, around certain patients scenarios that just are stories that you would think we made up. It's just they were so out of the ordinary. And the OCM model didn't necessarily have a lot of support for those kinds of situations. I feel like the EOM model because it's very much disease-specific driven has some potential to address some of those outliers. And those are the things that, with a full-risk model, we're really worried about those scenarios that you would never believe happen, but they really do happen. And we actually in OCM had a fair number—which I don't know why, if it's just us, or that's in general—of patients that had two primaries, which created a lot of complication about where the patient was categorized as far as our target.
So, we learned a lot about that. We learned a lot about just the challenges of coordination of care. Coordination of care isn't just something that happens inside your practice; in many cases it's what happens outside of your practice. It's your coordination with the pulmonologist, the cardiologist, the rheumatologist, the infectious disease, the nephrologist, and all the people that are involved in taking care of cancer patients who are super complicated and have many comorbid conditions.
And so, we learned a lot about that. We learned a lot about the fact that when we were sending patients for a pulmonology appointment or a cardiology appointment, that in Dallas–Fort Worth, it is generally a 6-week wait to get into those kind of specialists. And so, we had to forge relationships and do things to sort of work around that problem in that system. So, we learned a lot in OCM. And I would consider a lot of those things sort of our practice-enhancement efforts we put into place in addition to the standard sort of centralized triage and centralized triage—intake, I'm sorry—and case management and risk stratification. And the reason that we signed a participation agreement for EOM is because we maintained those sort of practice-enhancement mindsets and functions from OCM in anticipation of this sort of the second generation, which is now EOM. So, I feel good about our sort of practice-enhancement structure and our ability to translate that into these seven disease sites.
What we're what we're not 100% up to speed on yet is the actuarial support and analysis around our specific targets. We just received our data or had access to our data, I believe, as of yesterday. It might have been Friday evening, but I think we grabbed it yesterday. So, we have some actuarial work to do with that. We actually, Ron, took our OCM data, ran it through at least our anticipated, EOM model before receiving our actual targets from EOM, to see were we even, you know, in the same ballpark as far as could we do this. And so, the analysis of our OCM data, running it through an anticipated EOM model, although there are some bumpy areas, we thought, "Well, this looks—this looks better than we thought."
And the last time that I was on a panel with Alex, actually, a while back she was walking us through how the targets were set through non-OCM, using non-OCM practices, and practice data, which we were not aware of until, actually, I heard Alex say that at the last panel that she and I were participating in. And that gave us a little sense of hope on that as well. And so, our next steps are, we're going to take the data we just got access to, run it back through our models, and use our actuarial support to do that, and see what our worst case scenario is, what our best case scenario, and what our actuarial feels is probably our most likely case scenario, and then come to determination from there whether we're going to participate.
These models do take some time to ramp up, and so there is no sort of grace period in this, from the standpoint of full risk. And you and I, Ron, you've run practices before. The last thing you want to do is get in front of your board six months later and tell them that everybody's comp is reduced because we didn't make the targets we were hoping to do, because those are generally career-limiting discussions.
Barkley: Yeah, I was going to say, you don't really want to do that. That's kind of career-limiting information.
Russo: Yeah, I know I don't really want to do that. So, I want to make sure we sort of dotted all the Is and crossed all the Ts on that and that we feel super comfortable that given the new data that we have and our historical experience and our practice-enhancement process that we've been through, that we can do this. We want to try and do it; that's the one thing I really want CMS hear from—I hear this from a lot of practices. We want to do this because we know it's more likely a semblance of what our future reimbursement structures are from all payers. It may not all be full risk, but it may be shared risk, and then sometimes to a full risk.
But we know we need to understand how to do population health in an oncology world; we do get that. Whether or not we can make this model work, we're still sort of analyzing. And some of the some of the challenges we're trying to understand right now, too, is do we need to investigate stop-loss insurance and what's the cost structure associated with that? So, my conversations at the board level, if we had a bad performance period, aren't as complicated and difficult.
We want to understand a little bit more the sort of social determinants of health and our equity project. Those are new things to us, and we think we have some really good ideas about that, but we don't know how effective they're going to be. We've already started on an equity project because we thought, "Well, let's give it a whirl and see how it goes." And we've had some really, really good luck with it. So, I'm actually kind of excited about that, but I think we've got some more work to do on that.
The other thing that we're really interested in is the whole care management at home thing. We've been working with some partners who do some home care—and I don't mean that from a home health standpoint, I mean that from an acute standpoint—and, boy, we're have a really good luck with some of that. So, and I mean that from the standpoint of symptom management and in ways that we can intervene.
Lastly, we're trying to figure out the right electronic communication tools with patients. Part of this effort in EOM is that we have effective electronic communication with patients. One of the things we did learn through the pandemic is we need to talk to people electronically, because at the time it was impossible to talk to him face to face, anyway. And over time nobody wants to talk to you anymore, anyway, they just want to talk electronically and via tech. And there are so many options out there, and so many different systems and so many different scenarios, including remote monitoring, which is a really cool idea, and we're actually piloting something with that right now.
So, got a lot of things going on, but over the next 30 days—hopefully less—we're going to be evaluating the data that came, seeing if it does make sense, and what our actuarials feel like our most likely scenarios are and make the determination, which I've got to get back to my board to get them up to speed, about completing our participation, at least for the beginning performance period. So that's kind of where we're at, Ron, with it.
Barkley: Yeah, really appreciate that, Barry. Great insights from somebody that's deep in the weeds with this on the ground and is going to be held accountable. So, appreciate all that.
Marissa, let's shift to you as an example of a participant that is smaller in size than Barry's practice. I'm kind of curious as to whether your deliberations as a smaller practice with ostensibly fewer resources––not necessarily, but ostensibly––if your thought process of the practice in deciding to participate might have been different than what Barry described. Or basically, how did you go about deciding? And then, you know in general, what are your expectations of the program?
Marissa Rivera, MBA: Thank you, Ron. And as you said, we are much smaller practice. We're not as sophisticated as Barry's practice. And in terms of deliberation––so, we were an OCM participant all the way through the end as well. And we had some success, actually. And so that that is what has given me hope. But this was a hard sell for the doctors because this involves financial risk.
And, you know, we don't have actuarials. But I had to put together like scenarios in order for the doctors to understand how the EOM works. Like, if we reach a certain target with them, what the performance-based payment would be. And then then there's this level of like in between where you don't lose anything, you don't gain anything. And then there's the performance-based recoupment. And so, we also reviewed our feedback reports and checked our weak points, and we had to assess, are we going to overcome our weak points so that we can be successful in EOM and we have to maximize our aggregate quality score in order to maximize the PBP.
So, you know, I know that I had to describe this program more than one time to the doctors, and we didn't sign up until you know, close to the deadline. We were on the fence for a long time. But you know, as the president of the practice said, I'm just an eternal optimist. I'd like to keep challenging ourselves, you know, so we could participate in value-based programs, so we can continue to improve on the quality of care and you know, at the most cost-effective manner. We'll just keep on improving.
So, that's actually the goal. And we want to be prepared for the future as well. Because I feel like if we don't, we're going to be so behind that we're, you know, we're not going to be able to participate in any other future programs.
Barkley: Do you have any particular areas that you're looking for additional clarity about before the program launches? Since we have CMMI here, they might want to hear about things that you're looking for that are that are a void.
Rivera: Something simple. So, on the billing of the MEOS. So, we bill for the MEOS, right, but we we have a lot of dual eligibles. Would the secondary be an automatic payment for us, because the system knows that the patient is a dually eligible patient? So, we just receive the extra $30?
Chong: So, those are great questions, and as Eileen mentioned before, we will be sharing more specific guidance on billing. So, billing on MEOS payments, billing on any of the benefit enhancements. So, Barry, what you spoke to about for, like any of the benefit enhancements that we have for, like home health, for instance, or, you know, doing visits within a patient's home.
Marissa, specifically for your question, though, we didn't––that was part of being, it's like, it's a sell to these physicians to participate in this program. The financial risk is a big part of it. We have been trying to be mindful to try to reduce the burden as much as we can to the extent that we're able to. So, in that particular instance for the operations component of billing for the MEOS, we have it set up within the system for the max, when you do your typical billing for fee-for-service claims, that there is a signal that essentially turns on if it recognizes it as a beneficiary that's dually eligible, so it shouldn't be any additional work for you all; you just bill for the MEOS payment for the beneficiary. If they are coded as being dually eligible for Medicare and Medicaid within that month, for that episode, you automatically receive the additional $30, or it's like a full $100 payment. So hopefully things like that help.
Rivera: All right. Thank you.
Barkley: Thank you all for your insights and before we sign off, I just offer that if you have any final comments or pearls of wisdom for our viewers about the EOM program that you'd like to share, now is the time to say so.
Russo: I'll jump in, Ron, I'll jump in Ron, and just say that, at this point, if you haven't already signed a participation agreement, and you haven't already filled out your stuff, it's a little late, right? I think it may be past the deadline for that. But if you have signed the participation agreement, I know a lot of practices executed it in the beginning and subsequently have decided that as they've done more analysis, that it is too risky. But I do think now that we have our target data directly from CMS that it is worth running the analysis to see, can you make this work and what is your worst-case scenario, and can you either reserve and/or purchase sort of stop-loss to offset that?
The more of us that participate in this, and I'm not saying ultimately that we will, because that's up to my board's decision. But the more practices that participate the better we understand it, and I hope the more feedback that CMS receives on potential tweaks and things that need to happen to the program to make it, you know, more sustainable over a long term.
So, hope everyone will give it a chance to look at, because I originally was––before I understood sort of how the target was developed––I was like, "Oh, my gosh, this is never going to work right." But I sort of got a different view of it. I'm going to take our data we're going to do some analysis. We're going to figure this out. We still might come out at the end a no. But I'm going into it with a thought process, as Marissa said, of let's see if we can make this work, and let's see if we can overcome our worst-case scenario, and let's see if we can build a program in oncology with a population management/population health mindset that can be extrapolated across payers on all fronts and not just the Medicare front.
Barkley: Great, thank you. And anyone else?
Chong: I think maybe if I can jump in here, I just want to say how helpful this video session was, actually, like how great insights from two practices who had experience in OCM, but two different practice profiles.
I actually want to give two pearls of wisdom, if that's okay. The first one that I would say is, again, I think, speaking to the challenges of balance that I mentioned earlier in balancing just such a wide variety of practices, who have different levels of support. This is not a model that's intended where the only way to succeed is, if you have a ton of resources and a ton of external consultants and support. So, my first pearl of wisdom is probably like, please don't hesitate to reach out to us directly, right, to ask for help on things, to reach out to your project officer or shoot me an email, or Eileen an email. We're really here to help and support and want to make this model a success.
I think even for two practices who have prior OCM experience, there's a lot of similarities in the methodology, for instance, in EOM and OCM. And even within this transition, I think, because of the required downsided risk, you're looking at the financial methodology a little bit more carefully. You're examining things a lot more carefully and to the extent that you have questions, please direct them to us, who are the creators of the methodology itself.
My second pearl of wisdom is, probably to also talk amongst with one another. And again, I think, keeping in mind that model implementation, even with prior value-based care experience, it takes time, right? And I would also point out as well, understand some of the concerns around the stop-loss, and for you know, Barry and Marissa, both of your practices, who are in OCM, would just also note that the stop-loss corridor is much smaller in EOM across both of the risk arrangements than it was in the alternative or original downsided risk arrangement. So, I think kind of comparing your comp comparison, you’re kind of comparing your experiences across there and really looking at kind of like what your actual losses would be. How often, even if you didn't earn a performance-based payment in an OCM, thinking about how close were you to the benchmark? Did you beat your benchmark, for example? So, I think those things are things to think about.
And then, finally, I just want to close by stating just how excited we are at CMMI for the upcoming launch of EOM in July. We know that embarking in value-based care in oncology, especially in a model test that requires that financial downside risk, can be very daunting. But we are just so encouraged by the commitment and dedication across CMS, the EOM participants, and the oncology stakeholder community. You know I feel really encouraged when hearing both you, Barry, and Marissa, just thinking about like very forward thinking in what care is going to be looking like and in the belief in the principles of value-based care. So, we really view this model test as a collaboration, and expect that in order for it to be successful, we really need to work together and learn from one another. And I very much look forward to that.
Barkley: Fantastic, thank you. And I do want to thank today's EOM panelists: Alexandra Chong, Eileen Witherspoon, Barry Russo, and Marissa Rivera.
We look forward to building on this conversation in upcoming Cancer Care Business Breakthrough videos, as well as during our annual Clinical Pathways Congress and Cancer Care Business Exchange Conference, which takes place October 6-8 in Boston.
I wanted to point out that we are planning to do a similar discussion at the meeting in person with CMMI and some practice participants from the perspective of what's going on 90 days post-launch, so that should be fun.
Registration for the conference is now open, and we hope to see you there in person. Thank you all for your interest in our Cancer Care Business Breakthroughs video series. Have a good day.
