ASCO submitted comments to the Centers for Medicare & Medicaid Services (CMS) in response to the agency’s Request for Information (RFI) on its conceptualized Oncology Care First (OCF) payment model. The RFI asks questions about improving the OCF concept and lessons learned from CMS’ Oncology Care Model (OCM), which is ending in 2021. ASCO answered CMS’ questions and recommended that the agency adopt the society’s recently updated Patient-Centered Oncology Payment (PCOP) model.
Among its recommendations for practice redesign activities, ASCO urged CMS to include high-quality clinical pathways as a care redesign activity, with pathway adherence representing both a quality and a cost measure. Oncology pathways — which are detailed, evidence-based treatment protocols that guide care for patients with specific types and stages of cancer — serve as an important tool for improving the quality of cancer care and reducing costs. Rather than requiring a single Medicare-specific pathway, ASCO has previously recommended that CMS recognize clinical pathway programs that adhere to ASCO criteria.
ASCO also encouraged CMS to consider an alternative to the total cost-of-care methodology, which holds physicians responsible for the list price of drugs. The society believes that physicians should instead be held accountable for the utilization of services, including drugs, through targeted cost and utilization measures that protect against potential stinting of care. ASCO’s comments cite PCOP’s methodology as an alternative that CMS can successfully adopt to account for resource use, including cancer drug treatments.
Most notably, ASCO recommended that CMS adopt its updated PCOP model, the ASCO Patient-Centered Oncology Payment: A Community-Based Oncology Medical Home Model.
“Through the framework laid out in the PCOP model, we believe CMS can achieve its goal of a truly multi-payer model that improves care delivery and reduces costs,” said ASCO President Howard A. "Skip" Burris, III, MD, FACP, FASCO, in the comments. “We encourage CMS to adopt this model also, either under CMMI or through waiver authority to local contractors.”
PCOP transforms cancer care using three major approaches: improved care delivery and coordination through an oncology medical home framework, which has shown improved outcomes and reduced costs; a performance-based reimbursement system that relies on patient-centered standards and transitions to bundled payments; and consistent delivery of high quality care using clinical pathways that adhere to ASCO criteria.
ASCO’s data show significant potential for PCOP to yield cost savings—up to 8% across the healthcare system—with a model that accommodates diverse practices and care settings and guides participants through its implementation.