In response to a request for information, the American College of Radiology® (ACR®) expressed several concerns in a December 13, 2019, comment letter about a potential Oncology Care First (OCF) Medicare payment model proposed by the Centers for Medicare and Medicaid Services (CMS) and the CMS Innovation Center (CMMI).
This OCF payment model would build off the current Oncology Care Model (OCM), would aim at including a multi-disciplinary approach to cancer treatment, and would suggest including radiation therapy and possibly imaging and lab tests in a broader oncology episode of care.
The proposed OCF model would pay a prospective monthly population payment for evaluation and management, and drug administrative services to medical oncologists who would be responsible for quality reporting, outcomes and risk.
The OCF performance-based payment episode would be triggered at the infusion of chemotherapy and would include six months of care, including all Part A and Part B services, as well as certain Part D expenditures.
In its comment letter, the ACR expressed its belief that the OCM and OCF models are medical oncology-centric and do not lay the proper groundwork for multi-disciplinary payment nor direct responsibility for the costs and outcome of the patient. It stressed that it is best to keep radiation oncology (RO) services outside of the OCF and pay either as fee-for-service or through the pending proposed RO model.
The ACR also suggested that CMS should omit the OCF practice date from the trend factor analysis used to annually update the RO model national case rates, if CMMI decides to implement the OCF as proposed with the inclusion of radiation therapy services.
Comments and questions may be directed to Samantha Porter, ACR economics and health policy analyst.