NPC Weighs in on CMS Oncology Care First Model

The National Pharmaceutical Council (NPC) submitted comments regarding the Centers for Medicare and Medicaid Services (CMS) Center for Medicare and Medicaid Innovation (CMS Innovation Center) informal request for information (RFI) on the Oncology Care First (OCF) Model. CMS’ RFI is intended to inform the agency’s efforts to improve health outcomes and quality of care for Medicare beneficiaries with cancer.

NPC has conducted and partnered on extensive research on quality measures; this research provided the foundation for NPC’s comments in five key areas:

• Electronic patient-reported outcomes (ePRO) measures (ePROMs) and implementation support: NPC supported the inclusion of ePROMs in the OCF model and suggested a stepwise approach to implementation, as well as offering incentives for OCF Model practices to participate. CMS could require the use of standardized items from validated PROMs but allow practices the flexibility to add these questions to existing tools or add their own questions to new tools to support clinical care, quality improvement and accountability. CMS could offer resources to support ePROM implementation, including a higher Year 1 Monthly Population Payment. Finally, CMS could plan ahead for PRO-PM development by requiring items related to key measurement areas: symptoms/symptom burden, emotional/social status, care concordance with goals and values and shared decision-making.
   
• Inclusion of additional quality measures: CMS has an opportunity to help fill oncology measurement gaps, improve outcomes measures (including those related to adverse events), encourage access to needed treatment via measures of appropriate utilization and care coordination, promote care that is in alignment with patients’ wishes and support participation in clinical trials.
   
• Patient involvement in all phases of program development and implementation: NPC noted that it’s important to engage with patients, caregivers and other stakeholder groups (including information technology vendors and biopharmaceutical manufacturers) to ensure that value is meaningfully defined from the patient perspective.
   
• Criteria for identifying nationally recognized clinical practice guidelines: CMS should clearly define criteria for guidelines under the OCF Model’s Enhanced Services requirements. Clinical pathways do not reliably meet NPC’s suggested guideline criteria of transparency during development, meeting codified standards and prioritizing high quality evidence, and therefore should not be used as proxies for guidelines in the OCF.
   
• Cell and gene therapy exclusion from episode payment: Following the precedent set in the Oncology Care Model (OCM), cell and gene therapies should be excluded from episode cost reconciliation in the OCF Model. The health benefits from these treatments often occur after the six-month timeframe set out by the CMS payment model, creating disincentives for the use of these therapies that may limit patient access to breakthrough therapies.

CMS anticipates that the new OCF model would begin in January 2021. NPC suggested that the CMS Innovation Center provide an opportunity for stakeholders to comment on additional and revised details of OCF Model prior to program implementation.

For additional information, check out NPC’s research with Discern Health, Improving Patient-Reported Outcomes in Oncology and Improving Oncology Quality Measurement in Accountable Care.