CMS recently announced the Enhancing Oncology Model (“EOM”), which will build on the Oncology Care Model that ended on June 30, 2022. EOM is the next phase in the Biden Administration’s Cancer Moonshot initiative and will run from July 2023 through July 2028. EOM aims to improve care coordination, quality and health outcomes while holding oncology physician practices accountable for total costs of care to make cancer care more affordable and accessible.
Under the voluntary EOM model, Physician Group Practices (“PGPs”) will be accountable for their patients’ health care quality and total spend during six-month episodes of care for Medicare patients with breast cancer, chronic leukemia, small intestine/colorectal cancer, lung cancer, lymphoma, multiple myeloma and prostate cancer. In furtherance of CMS’s goal of advancing health equity, participants will be required to report patient demographic data and develop plans to decrease health equity gaps amongst the patients that they serve.
Participants will have the option to receive a Monthly Enhanced Oncology Services (“MEOS”) payment for the Enhanced Services provided to patients, including patient navigation, care planning, collection of electronic patient-reported outcomes and screening for social needs that may affect treatment, such as transportation issues and nutritional needs. The MEOS payment will be higher for beneficiaries dually eligible for Medicare and Medicaid. EOM participants will be able to qualify for a retrospective performance-based payment based on the quality of care and savings, but participating providers will also take on downside risk from the beginning of the program and could owe CMS performance-based recoupment. EOM includes two (2) risk arrangements, both of which are expected to qualify as a Merit-Based Incentive Payment System Alternative Payment Model beginning July 2023.
EOM will be a multi-payer model in the hopes that private payers, Medicare Advantage plans and state Medicaid agencies will apply and provide consistency throughout the model. PGP’s across the U.S. are eligible to apply.
Practical Takeaways
CMS encourages oncology practices to apply for participation. Applications will be accepted through September 30, 2022. If your practice has questions regarding EOM design, key elements or the application process, please contact:
- Erin Drummy at (317) 977-1414 or edrummy@wp.hallrender.com;
- Lori Wink at (414) 721-0456 or lwink@wp.hallrender.com;
- Regan Tankersley at (317) 977-1445 or rtankersley@wp.hallrender.com; or
- Your primary Hall Render contact.
Special thanks to Derek White, Summer Associate, for his assistance with this article.
Hall Render blog posts and articles are intended for informational purposes only. For ethical reasons, Hall Render attorneys cannot—outside of an attorney-client relationship—answer specific questions that would be legal advice.
