Can the OCM Perform as Intended?

Andrew L. Pecora, MD

With great anticipation, CMS, through the Center for Medicare & Medicaid Innovation (CMMI), has launched an initiative called the Oncology Care Model (OCM) that is designed to maintain clinical outcomes and reduce the total cost of care. The obvious first question is, has it been designed to do so? On June 9, CMMI put out a document titled, “OCM Clinical Data and Quality Measures.” The intent was to provide a general understanding of the OCM requirements for reporting clinical and quality measures data, highlight the actual measures to be reported within the initial OCM performance period, and provide practices with information to assist in qualifying OCM fee-for-service (FFS) beneficiaries. Central to the thesis of how OCM will improve outcomes and reduce total cost of care are care coordination and patient centeredness. Several domains from CMS’s National Quality Strategy were selected as quality measures, including communication and care coordination, person and caregivercentered experience and outcomes, clinical quality of care, and patient safety.

The plan is to start with claims-based measures to be compared against national benchmarks within the 6-month episodes. These include OCM-1, risk-adjusted all-cause hospital admissions; OCM- 2, risk-adjusted emergency department (ED) visits; and OCM-3, patients who died following admission to hospice for 3 or more days. Clearly, less is better for OCM 1 and 2, and more is better for OCM 3. Next is OCM-6, patient-reported experience using Consumer Assessment of Healthcare Providers and Systems (CAHPS) surveys to be performed by an independent contractor.

The measures the OCM will require practices to report to the OCM registry on a quarterly basis include OCM 4a and 4b, quantifying and outlining a plan of care for pain; OCM-5, screening and plan for treating depression; OCM-7, adjuvant hormone therapy received by patients with high- and very highrisk prostate cancer; OCM-8 and OCM-9, adjuvant chemotherapy recommended for or received by patients with stage III colon and stage Ib-III breast cancer; OCM-10 and OCM-11, appropriate therapy received by patients with HER2 positive breast cancer and ER/PR positive breast cancer; and OCM-12, OCM-24, and OCM-30, which involve documentation of patient medications, care plans, and specialist reports, respectively.

It appears that all Medicare FFS beneficiaries who meet eligibility are included and initiate with the first dose of chemotherapy. Over 60 types and subtypes of cancer are eligible. This is a noble and important effort by CMMI and a good first step to achieving the primary goal to improve outcomes and reduce cost. Obviously what are missing are clinical outcome measures for most cancers and measures of truly relevant clinical outcomes, such as progression-free and overall survival, time to best response, minimal residual disease assessment, and incidence and severity of toxicities. It has taken decades to begin to realize the promise of precision medicine and we cannot move backward for expediency or ease. So, will this improve clinical outcomes and reduce total cost of care? In the current form maybe but, regardless, kudos to CMMI for a bold first step.