The Center for Medicare & Medicaid Innovation: Preliminary design for an oncology-focused model Introduction to Specialty Practitioner Payment Models The Center for Medicare & Medicaid Innovation (Innovation Center) has a growing portfolio testing various payment and service delivery models. These models aim to achieve better care for patients, to improve health in our communities, and to lower costs through improvement of our health care system. The Innovation Center is exploring specialty practitioner payment models that focus on services that are typically furnished by specialists1. With input from stakeholders, the Innovation Center has identified cancer care, particularly chemotherapy treatment, as an area where health care and care coordination can be improved while reducing spending. The Innovation Center is developing an oncology payment model, currently referred to as the Oncology Care Model (OCM), to test the effect of better care coordination, improved access to practitioners, and appropriate clinical care on improving health outcomes at a lower cost. This design paper is intended to share the current thinking regarding a potential oncology episode-based payment model test. Aspects of the model are subject to change. If the Innovation Center decides to implement OCM, the Innovation Center will publish the final model with additional detail regarding participation in the model on the Innovation Center website. Overview of OCM The goal of OCM would be to utilize appropriately aligned financial incentives, including performance-based payments, to improve care coordination, appropriateness of care, and access for beneficiaries undergoing chemotherapy, resulting in improved health outcomes, higher quality care, and lower expenditures. Financial incentives for appropriate care should reduce health care expenditures as participating practices collaboratively and comprehensively address the complex care needs of the beneficiary population receiving chemotherapy treatment, while decreasing the use of services that do not improve health outcomes. OCM would target chemotherapy treatment and the spectrum of care provided to a patient during a 6-month episode following the start of chemotherapy treatment. Participants would be physician practices that furnish chemotherapy treatment, and would be expected to engage in practice transformation to improve the quality of care they deliver. This transformation would be driven by the requirements practices must fulfill in order to participate in OCM, including: Employ one or more designated patient navigator/care coordinators; Document a care plan that contains the 13 components in the Institute of Medicine Care Management Plan outlined in the Institute of medicine report, “Delivering High-Quality Cancer Care: Charting a New Course for a System in Crisis”;2 Provide and attest to 24 hours a day, 7 days a week patient access to an appropriate clinician who has real-time access to practice’s medical records; 1 http://innovation.cms.gov/initiatives/Specialty-Practitioner/ Institute of Medicine Report. Levit L, Balogh E, Nass S and Ganz P, ed. Delivering High-Quality Cancer Care: Charting a New Course for a System in Crisis. 2013. The full list of components is in Appendix B. 2 1 08.12.2014 The Center for Medicare & Medicaid Innovation: Preliminary design for an oncology-focused model Utilize data for continuous quality improvement; and Use an ONC-certified EHR and attest to Stage 2 of meaningful use by the end of the fourth model performance year. A number of quality measures would be used to monitor and evaluate the model and to provide continuous feedback to practices throughout the model. In addition, some measures would be used to adjust the performance-based payments. A preliminary list of measures is in Appendix A. Multipayer Model OCM would be a multi-payer model that includes Medicare fee-for-service (OCM-FFS) and other payers (OCM-OP) working in tandem to leverage the opportunity to transform care for oncology patients across the population. Medicare beneficiaries represent approximately 50 percent of oncology patients. This is a significant number, but engaging other payers would allow OCM to drive comprehensive care redesign at the practice level and improve cancer care for more patient populations. Other payers beyond Medicare FFS would be able to participate in OCM by entering into a Memorandum of Understanding (MOU) with the Innovation Center. There may be differences between OCM-FFS and OCM-OP in certain areas, such as selection of performance-based payment measures. However, the approach to practice transformation would be consistent across OCM. Application Process The Innovation Center would require Letters of Intents (LOIs) from payers and practices, which (with permission) would be posted publicly to facilitate cooperation between payers and practices prior to model implementation. Payers and practices would separately apply to participate in OCM. During the participant selection process, the Innovation Center would prioritize physician practices that would be participating in OCM with Medicare FFS and other payers. Target Population and Geographic Scope Eligible beneficiaries for OCM-FFS would include beneficiaries who are eligible for Medicare Part A and enrolled in Medicare Part B; have Medicare FFS as their primary payer and are not covered under United Mine Workers; begin receiving an initiating cancer therapy for an included cancer type from a model participant; and do not have end-stage renal disease. The Innovation Center aims to implement OCM nationally. However, the geographic scope of the model may be affected by the level of participation from other payers. OCM Payments OCM-FFS would incorporate a two-part payment approach for participating oncology practices, creating incentives to improve the quality of care and furnish enhanced services for beneficiaries undergoing chemotherapy treatment for a cancer diagnosis. OCM-FFS’ two forms of payment would include a monthly per-beneficiary care management payment for Medicare FFS beneficiaries, as well as a retrospective performance-based payment for OCM-FFS episodes. The perbeneficiary-per-month (PBPM) payment for enhanced services would offer participating practices financial resources to aid in effectively managing and coordinating care for Medicare FFS beneficiaries, while the performance-based payment 2 08.12.2014 The Center for Medicare & Medicaid Innovation: Preliminary design for an oncology-focused model would incentivize participating practices to lower the total cost of care and improve care for beneficiaries over the 6month episode period. The PBPM payment amount would be based on the estimated practice costs to furnish the enhanced services in OCM. The performance-based payment would be calculated based on the practice’s achievement of Medicare savings and achievement on the performance-based payment measures listed in Appendix A. Both payments would be in addition to the existing Medicare FFS payments from the Medicare Trust Fund. Episode Definition Included Cancer Types OCM would include all cancer types. The Innovation Center would consider episodes to be potentially eligible for a performance-based payment regardless of cancer type, unless the Innovation Center is unable to set accurate benchmarks for certain low-volume cancers. The Innovation Center is currently analyzing benchmarking methodologies in order to maximize the number of beneficiaries eligible for a performance-based payment. Episode Initiation OCM-FFS episodes would initiate on the date of an initial chemotherapy administration claim or an initial Part D chemotherapy claim and would not include services provided prior to that date. The Innovation Center has devised a list of likely and possible chemotherapy drugs that would trigger OCM-FFS episodes. The list includes endocrine therapies but excludes topical formulations of drugs. Services Included in the Episode OCM-FFS episodes would include all Medicare A, B, and D services that FFS beneficiaries receive during the episode period. Episode Termination OCM-FFS episodes would terminate six months after a beneficiary’s chemotherapy initiation or when the beneficiary dies prior to the end of the six month chemotherapy episode. Beneficiaries continuing to receive chemotherapy at the end of an episode would initiate a new episode, with a maximum of two episodes per beneficiary. Beneficiary Attribution Eligible beneficiaries would be attributed to the OCM-FFS participant that is actively managing each beneficiary’s cancer treatment using an attribution rule that would incorporate information from claims for chemotherapy administration and evaluation & management services. Eligible Medicare beneficiaries would be notified by participating practices about OCM and its goals to improve their care while reducing Medicare expenditures. Practices would advise beneficiaries that they have the freedom to choose their health care providers and may choose a provider who is not participating in OCM. 3 08.12.2014 The Center for Medicare & Medicaid Innovation: Preliminary design for an oncology-focused model Benchmarking and Performance-Based Payment Calculation of Possible Performance-Based Payments The Innovation Center would calculate risk-adjusted benchmark expenditures based on historical data, trend the benchmark expenditures to the performance period, and incorporate a discount that Medicare would retain to set the target price for performance period episodes. The Innovation Center would leverage regional or national data to increase precision for target prices for practices with a low number of episodes. The Innovation Center would perform a retrospective reconciliation of actual performance period Medicare FFS expenditures against the target prices, and participants would be paid up to the full difference through the performance-based payment. The amount of the performance-based payment would potentially be reduced or eliminated if a participant’s performance on a range of measures does not exceed established thresholds (see the Appendix A for the preliminary list of performance-based payment measures). Risk Adjustment Factors The Innovation Center would risk adjust for characteristics that predict Medicare expenditures in the episode. In the first year risk adjustment factors would include only those in Medicare administrative claims data. Examples include: beneficiary characteristics, episode characteristics, disease characteristics, and types of services furnished. The Innovation Center would collect additional information from practices, including cancer staging information, to consider as risk adjustment factors in future performance years of OCM. Risk Arrangements and Distribution of Performance-Based Payments OCM-FFS would feature semi-annual retrospective reconciliation of episodes and distribution of performance-based payments. The Innovation Center would remove OCM-FFS participants who do not achieve performance-based payments by the end of the third model year. OCM-FFS would include only one-sided risk in the first model year. In the one-sided risk arrangement, any OCM-FFS participant whose performance year actual expenditures exceed the target price would not be financially responsible for additional costs. After the second model year, participants would be able to switch to two-sided risk on a semiannual basis, in which the participant would be financially responsible for Medicare FFS expenditures that exceed the target price. The Innovation Center would expect to set the discount at a lower rate for participants in the two-sided risk arrangement. Beneficiary Experience Medicare FFS beneficiaries would be notified of their physician’s participation in OCM and the goals of OCM. Participating practices would be required to work with the beneficiary to establish treatment goals and care plans. In addition, the practice will be required to educate the beneficiary on the expected response to treatment and treatment benefits and harms, including common and rare toxicities and how to manage these toxicities, as well as short-term and late effects of treatment. The Innovation Center would monitor many aspects of the beneficiaries’ care to ensure that 4 08.12.2014 The Center for Medicare & Medicaid Innovation: Preliminary design for an oncology-focused model appropriate, high-quality care is furnished to OCM beneficiaries. The Innovation Center would also monitor the beneficiary’s performance status during the chemotherapy episode. Summary of Opportunity OCM would offer individuals with cancer the opportunity to benefit from better quality care with a focus on enhanced care-coordination services and patient-centered care; practices the opportunity to improve care for their patients, lower costs, restructure to furnish more comprehensive care for oncology patients, and engage with quality and cost data that would inform care redesign; and payers the opportunity to improve care for their members, lower costs, and engage with quality and cost data that would inform changes to quality monitoring and payment delivery. 5 08.12.2014 The Center for Medicare & Medicaid Innovation: Preliminary design for an oncology-focused model Appendix A: Oncology Care Model Practice Requirements, Performance-Based Payment Measures, and Quality Monitoring Measures Purpose Quality Domain Practice Requirements Communication and Care Coordination Recommended practice requirement or quality measurement Employment of one or more designated patient navigators/care coordinators Attestation of meaningful use of electronic health records (EHRs) certified by the Office of the National Coordinator for Health Information Technology (ONC) Electronic documentation of a care plan that contains the 13 components in the IOM Care Management Plan Provision of and attestation to continuous patient access (24 hours per day, 7 days per week) to an appropriate clinician who has real-time access to practice’s medical record Attestation that beneficiaries are treated with therapies compliant with nationally recognized clinical guidelines or have documented reason for not following guidelines Number of emergency department visits per attributed OCM-FFS beneficiary per OCM-FFS episode Number of hospital admissions per attributed OCM-FFS beneficiaries per OCM-FFS episode Percentage of all Medicare FFS beneficiaries managed by a practice who are admitted to hospice for less than 3 days Percentage of all Medicare FFS beneficiaries managed by a practice who experience more than one emergency department visit in the last 30 days of life Performancebased payment Person-and CaregiverCentered Experience and Outcome Communication and Care Coordination Quality Monitoring 6 08.12.2014 Percentage of attributed OCM-FFS beneficiary face-to-face encounters with the participating practice in which there is a documented plan of care for pain AND pain intensity is quantified Score on patient experience survey (CAHPS as modified by the evaluation contractor) Percentage of attributed OCM-FFS beneficiary face-to-face encounters in which the patient is assessed by an approved patient-reported outcomes tool. This would include a minimum of the PROMIS tool short forms for anxiety, depression, fatigue, pain interference, and physical function Percentage of attributed OCM-FFS beneficiaries that receive psychosocial screening and intervention at least once per OCM-FFS episode Percentage of attributed OCM-FFS beneficiaries with at least one palliative care consultation per OCM-FFS episode Mortality rates of attributed OCM-FFS beneficiaries, risk-adjusted Number of emergency department visits per attributed OCM-FFS beneficiary in the 6 months following the OCM-FFS episode Number of hospital admissions per attributed OCM-FFS beneficiary in the 6 months following the OCM-FFS episode Number of hospital readmissions per attributed OCM-FFS beneficiary during the OCM-FFS episode and the following 6 months Number of ICU admissions per attributed OCM-FFS beneficiary during the OCM-FFS episode and the following 6 months Proportion of all Medicare FFS beneficiaries managed by a practice not NQF # Source Reported by practice Collected by CMS Reported by practice Reported by practice Reported by practice Claims data Claims data #0216 Claims data #0211 Claims data #2100 Reported by practice Administered by CMS contractor Reported by practice Reported by practice Reported by practice Claims data Claims data Claims data #1789 Claims data Claims data #0215 Claims data The Center for Medicare & Medicaid Innovation: Preliminary design for an oncology-focused model Purpose Quality Domain Clinical Quality of Care Population Health Efficiency and Cost Reduction 7 08.12.2014 Recommended practice requirement or quality measurement admitted to hospice Proportion of all Medicare FFS beneficiaries managed by a practice receiving chemotherapy in the last 14 days of life Percentage of attributed OCM-FFS beneficiaries that receive a follow-up visit from the participating practice within 7 days after discharge from any inpatient hospitalization Percentage of face-to-face encounters between an attributed OCM-FFS beneficiary and a participating practice which include medication reconciliation NQF # #0210 Source Claims data Claims data Reported by practice Breast Cancer: Hormonal therapy for Stage IC-IIIC (ER/PR) Positive Cancer in OCM-FFS beneficiaries #0387 Reported by practice (or claims data once stage is reported) Breast Cancer: Combination chemotherapy is considered or administered within 4 months (120 days) of diagnosis for women under 70 with AJCC T1c, or Stage II or Stage III hormone receptor negative breast cancer in OCM-FFS beneficiaries #0559 Reported by practice Colon Cancer: Chemotherapy for Stage IIIA through Stage IIIC OCM-FFS beneficiaries with colon cancer #0385 Reported by practice (or claims data once stage is reported) Colon Cancer: Adjuvant chemotherapy is considered or administered within 4 months (120 days) of surgery to OCM-FFS beneficiaries under the age of 80 with AJCC III (lymph node positive) colon cancer #0223 Reported by practice Prostate Cancer: Adjuvant hormonal therapy for high-risk OCM-FFS beneficiaries #0390 Reported by practice (or claims data once stage is reported) Percentage of OCM-FFS beneficiaries with documented ECOG, Karnofsky, or WHO performance status assessment prior to OCM-FFS episode initiation and at episode conclusion Percentage of attributed OCM-FFS beneficiaries that receive tobacco screening and cessation intervention at least once per OCM-FFS episode Percentage of attributed OCM-FFS beneficiaries that have an Influenza Immunization Number of attributed OCM-FFS beneficiaries enrolled in clinical trials at any point during an OCM-FFS episode Prescription drug utilization by attributed OCM-FFS beneficiaries under Medicare Part B and Part D Radiation utilization by attributed OCM-FFS beneficiaries Imaging utilization by attributed OCM-FFS beneficiaries Post-acute provider utilization by attributed OCM-FFS beneficiaries Outpatient therapy service utilization by attributed OCM-FFS beneficiaries Reported by practice #0028 Reported by practice #0041 Claims data Claims data Claims data Claims data Claims data Claims data Claims data The Center for Medicare & Medicaid Innovation: Preliminary design for an oncology-focused model Appendix B: Components of the IOM Care Management Plan 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. Patient information (e.g., name, date of birth, medication list, and allergies) Diagnosis, including specific tissue information, relevant biomarkers, and stage Prognosis Treatment goals (curative, life-prolonging, symptom control, palliative care) Initial plan for treatment and proposed duration, including specific chemotherapy drug names, doses, and schedule as well as surgery and radiation therapy (if applicable) Expected response to treatment Treatment benefits and harms, including common and rare toxicities and how to manage these toxicities, as well as short-term and late effects of treatment Information on quality of life and a patient’s likely experience with treatment Who will take responsibility for specific aspects of a patient’s care (e.g., the cancer care team, the primary care/geriatrics care team, or other care teams) Advance care plans, including advanced directives and other legal documents Estimated total and out-of-pocket costs of cancer treatment A plan for addressing a patient’s psychosocial health needs, including psychological, vocational, disability, legal, or financial concerns and their management Survivorship plan, including a summary of treatment and information on recommended follow-up activities and surveillance, as well as risk reduction and health promotion activities 8 08.12.2014