Reacting to the Results of the First Performance Period of OCM

The first results of the Oncology Care Model (OCM), a 5-year bundled payment demonstration from CMS, were released recently, and at a session at the National Community Oncology Dispensing Association Spring Forum 2018, Mike Fazio of Archway Health discussed the reconciliation statements from the first performance period of OCM, and where practices can look to make improvements going forward.

Archway Health is focused 100% on bundled payments and is helping 23 practices that are participating in OCM, which launched in July 2016. OCM is a bundled payment demonstration that focuses on care coordinationm, with improved outcomes and cost savings being monitored by CMS. There are more than 190 organizations and 16 health plans participating in OCM.

There are 2 risk options, but currently all participating practices are in the upside-only model with no participants in the down-side risk model. For now, that’s probably a smart decision, Fazio said, since practices and health systems will be better off to stay in the 1-sided risk model until they have the experience to take on 2-sided risk.

For instance, of the health systems and practices that Archway works with, most did not earn savings in the first performance period. “This was expected,” Fazio explained, and Archway told its clients that was likely.

There will be 8 more reconciliation statements over the remaining course of the demonstration, with the next one slated for August.

“The reaction so far has been not good from our client base,” Fazio admitted. “From our standpoint, our job is to validate that the reconciliations were correct.”

Archway is determining if CMS ran its calculations correctly, and if there are variances, that data can be taken to CMS to question if the statement is correct or if something needs to change in OCM moving forward. Fazio added that CMS is open to feedback, since it doesn’t want participants to drop out of the program.

Archway is sending a survey around to its clients to get feedback on the following areas and results of the OCM:

• Beneficiary attribution, such as whether or not the attribution list from CMS was consistent with the practice’s own
• Performance-based payment, such as whether or not the practice was able to interpret it or understand why it wasn’t earning a payment
• Monthly-enhanced oncology service recoupment, including if the practice was subject to a recoupment and, if so, how much, or if it is planning to contest it

There are aspects of the reconciliation statement that the practices can contest, such as attribution and cancer type. However, for anything a practice plans to contest, it has to be able to supple data to CMS, Fazio said.

One of the biggest benefits of participating in OCM is the data. CMS is providing participants with raw claims information for free, because it wants practices to use the data to find out where savings opportunities are. However, CMS doesn’t help practices analyze the data, which can be a challenge.

Archway works with some large hospital systems that realized they weren’t able to analyze the data on their own, despite having a team. “Never mind independent practices that don’t have an analytics team,” Fazio said.

But there is a lot that can be done with the claims data, and Archway has narrowed it down to 3 main questions:

1. How are we doing? Before the reconciliation statement, Archway tells practices if they are on track for savings and how they compare with other practices.
2. What are key drivers for performance? This includes examining why a practice might be off track or how it is doing on the 3 main measures: hospitalizations, emergency department use, and hospice use.
3. What can you do about it?

Most practices are already looking at hospital use as a big source of savings, but there are other areas they can be looking at to perform better. Practices are paying more attention to end-of-life care. CMS has been pushing increased palliative care and hospice use as strategies that can actually decrease costs. However, most practices are still in the early stages of figuring out how to operationalize end-of-life care at a practice level, Fazio explained.

Practices are also starting to look at drug regimens by cancer type to see if there are drugs that have the same outcomes but cost less from CMS’ perspective.

“Those are conversations that are hard to have among practices and physicians at practices, but those are conversations that are starting to happen,” Fazio said.