Mike Fazio Addresses Risk Adjustment in OCM, OCF Due to COVID-19

The coronavirus disease 2019 (COVID-19) pandemic is going to test the new risk adjustment in the Oncology Care Model as patients delay care, said Mike Fazio, senior vice president of Client Services at Archway Health.

Transcript

There has been a lot of delayed care and a lot of delayed cancer diagnoses because of the pandemic. How do you expect that this is going to impact practices participating in models like Oncology Care Model (OCM) and planning to transition into Oncology Care First (OCF)?

Well, you know, it's certainly going to be a test of CMS’s risk-adjusted price and methodology they have in place. They are implementing a metastatic risk adjustment in PP [performance period] 7. So, we'll see what that looks like for the first time in February. That's when reconciliations for PP7 will be released. And why that's important is, is if what we're hearing is true in that, you know, the delay in care results in a higher acuity patient, and possibly advanced disease, then that's where that metastatic adjustment will come into play from a pricing level. So, as costs rise, because of that, will the risk adjustment in metastatic adjustment that CMS has implemented work to adjust for those instances? So, time will tell about that.

We are seeing the COVID diagnoses being flagged in other programs like BPCI [Bundled Payments for Care Improvement] Advanced. We're looking at those claims as those come in. And those patients are, not surprisingly, very expensive. And so, in those programs, we get data every month, and we have more data to see how that's starting to affect those models. And so, it's still early to see how patients that have a COVID diagnosis will impact OCM. And as we know, CMS did provide some flexibilities for practices in OCM, for really through PP9—so, through the end of the year. So, what CMS comes up with for an adjustment in 2021, now that the program has been expanded to factor in patients that have a COVID diagnosis, we'll have to see what they come up with there.

But the big question, I think, for OCF is how will the baseline period for practices that will take on OCF be adjusted because of COVID? So, given that the baseline is likely to be most of 2020—and given that this has been an anomaly—how will CMS adjust for that? And maybe if they use part of 2021 in the baseline period for OCF, again, how will that be adjusted given that it's not a typical trend? So, that's a big challenge for CMS to work out. And we'll be staying tuned to see how they address that.