On Sep. 6, 2022 OneOncology submitted a detailed comment letter on important sections of the Medicare Physician Fee Schedule Proposed Rule for calendar year 2023 with significant implications for the Center for Medicare and Medicaid Innovation’s Enhancing Oncology Model (EOM).

Overall, the comment letter emphasized OneOncology’s support for value-based care in oncology and specifically emphasized support for community oncology participation in the Enhancing Oncology Model recently unveiled by the Center for Medicare and Medicaid Innovation (CMMI).

For more insight into EOM, note our prior blog post by Dr. Davey Daniel, Chief Medical Officer of OneOncology.

The primary purpose of submitting these comments is to address specific policies within the 2023 MPFS Proposed Rule that impact EOM participation and that are largely influenced through this formal public comment process for the Proposed Rule. Therefore, this letter is not intended to be a comprehensive account of all of the important considerations and policy recommendations regarding EOM and the 2023 MPFS that OneOncology supports.

The four main EOM-related policy positions discussed in the letter include:

1. OneOncology supports CMS’s reconsideration of the removal of the lump sum incentive payment for Advanced APM participation.
   Impact for practices: It’s important that CMS adequately incentivize RA-2 participation to a degree that is consistent with the additional risk financial risk practices would assume if they participate in RA-2.
   
2. OneOncology supports CMS’s current proposal that participating in the Advancing Cancer Care MIPS Value Pathway (MVP) should remain voluntary for oncology practices participating in MIPS, and we would currently recommend that CMS avoid setting any future target for making this MVP mandatory for cancer care providers participating in MIPS. 
   Impact for practices: It’s critical for practices to retain the optionality to select the quality measures, interoperability measures, improvement activities, and cost measures that best apply to their practice. Limiting the choices that practices have in meeting MIPS requirements could drastically increase the administrative burden associated with full MIPS participation for practices that don’t participate in EOM.  
   
3. OneOncology urges CMS to reconsider the requirement that participants in the more advanced Risk Arrangement option (RA-2) of CMMI’s Enhancing Oncology Model (EOM) also must meet APM patient volume or APM-related Medicare revenue thresholds to qualify for Advanced APM status.  
   Impact for practices: It’s important that practices who participate in the more advanced risk arrangement of EOM have the opportunity to obtain the incentives associated with Advanced APM participation.
   
4. OneOncology urges CMS to retain the option for participants in RA-2 of EOM to have Advanced APM Participant status assigned at the entity-level.  
   Impact for practices: Similar to the consideration above, it is important that CMS maintains its current policy, which would make it more likely that a practice that participates in EOM RA-2 would gain the incentives of Advanced APM participation, and would ensure that these incentives would be applied to all of a practice’s individual providers that the practice includes in its EOM participating provider list that it submits to CMMI.

OneOncology will continue to work with the key oncology professional associations, such as the Community Oncology Alliance (COA), the American Society of Clinical Oncology (ASCO), and the Association of Community Cancer Centers (ACCC) to advocate for policies that advance value-based cancer care by: (1) promoting access to highest quality care in the community setting for patients with cancer and blood disorders; (2) enhancing the patient experience; (2) minimizing the cost of cancer care for patients, payers and employers; (4) supporting the care teams that serve patients with cancer and blood disorders every day.

The full text of the letter is available here.