Redesigning the Oncology Care Model

Redesigning the THISTHIS IS ISTHIS THE THE IS TITLE TITLE THE OF TITLEOF THE THE OF DOCUMENT DOCUMENT THE DOCUMENT | | REMEDY REMEDY | REMEDY PARTNERS PARTNERS PARTNERS | | MAY MAY | 2019 2019 MAY 2019 PAGE:PAGE: PAGE:4 4 4 THIS IS THE TITLE OF THETHIS DOCUMENT IS THE TITLE | OFREMEDY THE DOCUMENT PARTNERS | | REMEDY MAY 2019 PARTNERS | MAYPAGE: 2019 4 PAGE: 4

Oncology Care Model

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Work Group Members Nick Bluhm Senior Director, Strategy & Government Policy, Remedy

François de Brantes Senior Vice President, Commercial Programs, Remedy

Ezekiel J. Emanuel, M.D., Ph.D.

Vice Provost for Global Initiatives, University of Pennsylvania • • ForFor• example, example,For example, this this is is thisthe the List isList the Bullet Bullet List Bulletstyle. style. style. • For example, this is the• ListFor Bullet example, style. this is the List Bullet style. Alice G. Gosfield, Esq. •• HereHere• is isHere another another is another sentence sentence sentence formatted formatted formatted in in List List inBullet Bullet List Bulletstyle. style. style. Principal,• Here Alice is G.another Gosfield sentence and• Associates, Hereformatted is anotherP.C. in List sentence Bullet style. formatted in List Bullet style. •• ForFor• example, example,For example, this this is is thisthe the List isList the Bullet Bullet List Bulletstyle. style. style. • For example, this is the• ListFor Bullet example, style. this is the List Bullet style. Michael Kolodziej, M.D. •• HereHere• is isHere another another is another sentence sentence sentence formatted formatted formatted in in List List inBullet Bullet List Bulletstyle. style. style. Vice• PresidentHere is and another Chief sentenceInnovation• Hereformatted Officer, is another ADVI in ListHealth sentence Bullet style. formatted in List Bullet style.

Valinda Rutledge ViewView and andView edit edit and this this edit document document this document in in Word Word in on Wordon your your on computer, computer, your computer, tablet, tablet, tablet,or or phone. phone. or phone. ViewVice andPresident, edit this Federal document Affairs,View in America’s and Word edit on Physiciansthis your document computer, Group in tablet,Word on or yourphone. computer, tablet, or phone. TEL:TEL: 855.395.6171 855.395.6171TEL: 855.395.6171 | | EMAIL: EMAIL: | [email protected] EMAIL:[email protected] [email protected] PowerofRemedy.comPowerofRemedy.comPowerofRemedy.com TEL:Special 855.395.6171 thanks to Mackenzie | EMAIL:TEL: [email protected] 855.395.6171 for her editing| EMAIL: and [email protected] 800research800 Connecticut Connecticut800 assistance. Connecticut Avenue, Avenue, Avenue,Floor Floor 3 3 East FloorEast Norwalk, Norwalk, PowerofRemedy.com3 East Norwalk, CT CT 06854 06854 CT 06854 PowerofRemedy.com 800 Connecticut Avenue, Floor 3800 East Connecticut Norwalk, CT Avenue, 06854 Floor 3 East Norwalk, CT 06854

Redesigning the OncologyTHISTHIS IS ISTHIS THE THE IS TITLE TITLECare THE OF TITLEOF THE THE OF DOCUMENT ModelDOCUMENT THE DOCUMENT | | REMEDY REMEDY | REMEDY PARTNERS PARTNERS PARTNERS | | MAY MAY | 2019 2019 MAY 2019 PAGE:PAGE: PAGE:4 4 4 THIS IS THE TITLE OF THETHIS DOCUMENT IS THE TITLE | OFREMEDY THE DOCUMENT PARTNERS | | REMEDY MAY 2019 PARTNERS | MAYPAGE: 2019 4 PAGE: 4 At Remedy, we realign the healthcare system to help providers collaborate more successfully

around episodes of care. Successful episode of care payment programs require technologies to link providers and patients, data analytics to measure and track performance, and systems to manage and report real-time financial andFinancialFinancial clinicalFinancial information. SummarySummary RemedySummary focuses on each of these Financialchallenges and developsFinancial Summary solutions that enableSummary providers to deliver higher quality patient outcomes at lower costs for all. UseUse this thisUse section section this section to to give give to a a briefgive brief a summary summarybrief summary of of your your of financials, financials, your financials, highlighting highlighting highlighting important important important points. points. points. Some Some of Someof the the of the Use this section to give a briefUse this summary section of to your give financials, a brief summary highlighting of your important financials, points. highlighting Some of important the points. Some of the Given our focus, we appreciate Medicare’ssamplesample interestsample text text in inin textthis this competition, indocument document this document indicates indicates patient indicates the the empowerment,name name the ofname of the the style ofstyle the applied, applied,style and applied, so so that that so you you that can can you easily easily can applyeasily apply the applythe same same the same sample text in this document indicates the name of the style applied, so that you can easily apply the same samplespecialist text in engagement. this document indicates Payment the modelsname of the formattingandformatting style insuranceformatting applied, again. again. so again. thatdesign you can that easily rely apply on these the same principles are formatting again. formatting again. essential for the Medicare and Medicaid programs to enlist those who are best positioned to improve care delivery. They’re also essential to private sector payers and purchasers of health care. •• ForFor• example, example,For example, this this is is thisthe the List isList the Bullet Bullet List Bulletstyle. style. style. To this end, we encourage the Centers for Medicare and Medicaid Services (CMS) to support the • For example, this is the• ListFor Bullet example, style. this is the List Bullet style. continuation and expansion of voluntary episode-based•• HereHere• is isHere another another is payment another sentence sentence sentence models formatted formatted formatted in in in Traditional List List inBullet Bullet List Bulletstyle. style. Medicare, style. • Here is another sentence• Hereformatted is another in List sentence Bullet style. formatted in List Bullet style. Medicare Advantage, and Medicaid. These models encourage integrated teams of clinicians and institutional and community providers to build business and care models that are driven by improvements in patient outcomes through:

Transparent Pricing: Straightforward pricing of clearly defined health care events, Informed Patients: Improved visibility into provider quality and relative value, and Smart Benefit Design: Complementary benefit design changes that support better shared decision-making.

They also create a platform from which the private sector can build its own programs, thus accelerating the move to value and away from fee-for-service medicine.

ViewView and andView edit edit and this this edit document document this document in in Word Word in on Wordon your your on computer, computer, your computer, tablet, tablet, tablet,or or phone. phone. or phone. View and edit this documentView in and Word edit on this your document computer, in tablet,Word on or yourphone. computer, tablet, or phone. TEL:TEL: 855.395.6171 855.395.6171TEL: 855.395.6171 | | EMAIL: EMAIL: | [email protected] EMAIL:[email protected] [email protected] PowerofRemedy.comPowerofRemedy.comPowerofRemedy.com TEL: 855.395.6171 | EMAIL:TEL: [email protected] 855.395.6171 | EMAIL: [email protected] Connecticut Connecticut800 Connecticut Avenue, Avenue, Avenue,Floor Floor 3 3 East FloorEast Norwalk, Norwalk, PowerofRemedy.com3 East Norwalk, CT CT 06854 06854 CT 06854 PowerofRemedy.com 800 Connecticut Avenue, Floor 3800 East Connecticut Norwalk, CT Avenue, 06854 Floor 3 East Norwalk, CT 06854

Redesigning the Oncology Care Model

Purpose of the Work Group In November 2018, Remedy convened thisTHISTHIS Work IS ISTHIS THE THE Group IS TITLE TITLE THE OF TITLEOFto THE THEcreate OF DOCUMENT DOCUMENT THE a DOCUMENT recommendation | | REMEDY REMEDY | REMEDY PARTNERS PARTNERS for PARTNERS the future | | MAY MAY | 2019 2019 MAY 2019 PAGE:PAGE: PAGE:4 4 4 THISof Medicare’s IS THE TITLE Oncology OF THETHIS DOCUMENT CareIS THE Model. TITLE | OFREMEDY This THE DOCUMENT modelPARTNERS tests | | whether REMEDY MAY 2019 PARTNERS additional | funding MAYPAGE: 2019 4 for enhancedPAGE: 4

services and financial incentives to improve the quality and appropriateness of care provided to

Medicare Fee-For-Service (FFS) beneficiaries can improve quality and reduce Medicare spending for patients undergoing chemotherapy for cancer. FinancialFinancialFinancial SummarySummary Summary FinancialFor many payers, oncologyFinancial Summary care is a principal Summary target of payment reform, given the high costs and variability inherent to these episodes of care. Payers have two objectives in mind for their UseUse this thisUse section section this section to to give give to a a briefgive brief a summary summarybrief summary of of your your of financials, financials, your financials, highlighting highlighting highlighting important important important points. points. points. Some Some of Someof the the of the oncology payment initiatives: Use this section to give a briefUse this summary section of to your give financials, a briefsamplesample summary samplehighlighting text text in inof textthis thisyour in document importantdocument financials,this document indicates points.indicates highlighting indicates Some the the name ofname important the ofname of the the points. style ofstyle the applied, applied,style Some applied, of so so the that that so you you that can can you easily easily can applyeasily apply the applythe same same the same sample text in this documentsample indicates text in the this name document of theformattingformatting indicates styleformatting applied, again. again.the name so again. that of youthe stylecan easily applied, apply so thethat same you can easily apply the same (1) To provide clinicians with financial incentives for managing total cancer costs of care; and formatting again. formatting again. (2) To reward groups for adherence to cost-effective and evidence-based clinical pathways.

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To compensate and reward clinicians for undertaking these additional efforts, Medicare supplemented the Part B professional and drug reimbursement with monthly care coordination payments to fund quality improvement initiatives. For practices that significantly reduced spending for patients experiencing episodes of care, Medicare paid out performance-based bonuses.

The Oncology Care Model is a promising start to Medicare’s payment reform for oncology care. As a Category 3 Model under the framework established by the Health Care Payment and Learning Action Network,1 the Oncology Care Model includes measures of quality as well as utilization for episodes of oncology care. The model has correctly identified most of the elements of cancer care management.2 And it has enabled practices to add additional functions to their group, supplementing their oncology care delivery with the capabilities for meeting the varied demands of their patients. Importantly it has moved practices away from a focus on fee-for-service

medicine and toward improving cancer care quality.

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Redesigning the Oncology Care Model

But the model needs refinement, which is the focus of this Work Group. There are several important changes that would enhance theTHISTHIS model IS ISTHIS THE THE IS TITLE andTITLE THE theOF TITLEOF THE THEknowledge OF DOCUMENT DOCUMENT THE DOCUMENT obtained. | | REMEDY REMEDY | REMEDYThe PARTNERS PARTNERS reporting PARTNERS | | MAY MAY | 2019 2019 MAY 2019 PAGE:PAGE: PAGE:4 4 4 THISrequirements IS THE TITLE OFare THE burdensome.THIS DOCUMENT IS THE TITLE 3| Moreover, OFREMEDY THE DOCUMENT PARTNERS the Clinical | | REMEDY MAY Episode 2019 PARTNERS categories | MAY PAGE:are 2019 not 4 intuitive to PAGE: 4

4 clinicians, who cannot easily apply and implement the concept as currently defined by Medicare. We stand ready to help Medicare define the triggers, categories, and substance of oncology Clinical Episodes. We recognize that this is not an inconsequential undertaking; and there are issues beyond the scope of this paper that will FinancialrequireFinancialFinancial the concerted SummarySummary attention Summary of clinical and actuarial Financialexperts. But MedicareFinancial Summary and patients will Summaryreap the rewards, if the definitions of the Episodes are clinically relevant to the way physicians think. UseUse this thisUse section section this section to to give give to a a briefgive brief a summary summarybrief summary of of your your of financials, financials, your financials, highlighting highlighting highlighting important important important points. points. points. Some Some of Someof the the of the Use this section to give a briefUse this summary section of to your give financials, a briefsamplesample summary samplehighlighting text text in inof textthis thisyour in document importantdocument financials,this document indicates points.indicates highlighting indicates Some the the name ofname important the ofname of the the points. style ofstyle the applied, applied,style Some applied, of so so the that that so you you that can can you easily easily can applyeasily apply the applythe same same the same Moreover, while the CMS Innovation Center has good intentions for the model, the current episode sample text in this documentsample indicates text in the this name document of theformattingformatting indicates styleformatting applied, again. again.the name so again. that of youthe stylecan easily applied, apply so thethat same you can easily apply the same definitions are highly constraining with regard to partnerships with local commercial plans. Very formatting again. formatting again. few commercial payers have chosen to participate in the OCM model of care, forcing practices to

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Current participants agree that prostate cancer, breast cancer, and perhaps lung cancer were the only episodes that had sufficient volume to justify participation outside of the Medicare fee- for-service population. Outside of these, the volume in other oncology clinical episodes for the under-65 commercial populations averaged 10-12 per year per payer.

The Incidence and Importance of Cancer Approximately 14 million individuals are currently living with cancer; nearly 2 million Americans are newly diagnosed with cancer each year.5 Medicare pays for the treatment of half of these newly-diagnosed.6 In the aggregate, annual costs for oncology care will reach nearly $158 billion in two years, a 27 percent increase since 2010.7 Demographic factors contribute to this remarkable increase, but new technology and therapeutics are equally as important.

3Abt Associates. Oncology Care Model: Evaluation of the Oncology Care Model: Performance Period One (Section 3.5.6) •• ForFor• example, example,For example, this this is is thisthe the List isList the Bullet Bullet List Bulletstyle. style. style. (December 2018). Retrieved on May 15, 2019, from https://innovation.cms.gov/Files/reports/ocm-secondannualeval-pp1.pdf. 4 • For example, this is the• ListFor Bullet example, style. this is the List Bullet style. Polite BN, The Road From Theory to Reality: Illuminating•• theHereHere• Complexity is isHere another another is another of sentence sentence Prospective sentence formatted formatted Cancer formatted in in Bundles. List List inBullet Bullet List J. Bulletstyle. Oncol.style. style. Prac. 2018;14(2):59-62. 5 • Here is another sentence• Hereformatted is another in List sentence Bullet style. formatted in List Bullet style. “SEER Cancer Statistics Review (CSR) 1975-2014,” National•• ForFor• Cancerexample, example,For example, Institute, this this is is thisthe theupdated List isList the Bullet Bullet AprilList Bulletstyle. style.2, 2018. style. 6 Statistical• For example, Brief #443: this Trends is the• List inFor Use Bullet example, and style. Expenditures this is the List for CancerBullet style. Treatment among Adults 18 and Older, U.S. Civilian Noninstitutionalized Population, 2001 and 2011. Retrieved•• HereHere on• November is isHere another another is another 13,sentence sentence 2019, sentence formatted from https://meps.ahrq.gov/data_files/formatted formatted in in List List inBullet Bullet List Bulletstyle. style. style. publications/st443/stat443.shtml.• Here is another sentence• Hereformatted is another in List sentence Bullet style. formatted in List Bullet style. 7Agency for Health Care Research and Quality. Total Expenses and Percent Distribution for Selected Conditions by Source of Payment: United States, 2014. Medical ExpenditureViewView Panel and andView Survey edit edit and this this Household edit document document this document Component in in Word Word in on Wordon Data. your your on computer, computer, your computer, tablet, tablet, tablet,or or phone. phone. or phone. View and edit this documentView in and Word edit on this your document computer, in tablet,Word on or yourphone. computer, tablet, or phone. TEL:TEL: 855.395.6171 855.395.6171TEL: 855.395.6171 | | EMAIL: EMAIL: | [email protected] EMAIL:[email protected] [email protected] PowerofRemedy.comPowerofRemedy.comPowerofRemedy.com TEL: 855.395.6171 | EMAIL:TEL: [email protected] 855.395.6171 | EMAIL: [email protected] Connecticut Connecticut800 Connecticut Avenue, Avenue, Avenue,Floor Floor 3 3 East FloorEast Norwalk, Norwalk, PowerofRemedy.com3 East Norwalk, CT CT 06854 06854 CT 06854 PowerofRemedy.com 800 Connecticut Avenue, Floor 3800 East Connecticut Norwalk, CT Avenue, 06854 Floor 3 East Norwalk, CT 06854

Redesigning the Oncology Care Model

New techniques in surgery and radiation, as well as developments in oncology medication, add to the treatment cost. 8 Historically, many believedTHISTHIS IS ISTHIS THE THE that IS TITLE TITLE THE the OF TITLEOF majority THE THE OF DOCUMENT DOCUMENT THE of DOCUMENT cancer-care-services | | REMEDY REMEDY | REMEDY PARTNERS PARTNERS PARTNERS costs | | MAY are MAY | 2019 2019 MAY 2019 PAGE:PAGE: PAGE:4 4 4 THISfor outpatient IS THE TITLE services,OF THETHIS DOCUMENT ISfollowed THE TITLE | by OFREMEDY inpatient THE DOCUMENT PARTNERS admissions | | REMEDY MAY and 2019 PARTNERS drug spending. | MAYPAGE: The2019 4 consulting firmPAGE: 4

Milliman analyzed trends in the changes of these services, observing that the per-patient cost of drugs is increasing at a much higher rate than other cost components, driven largely by specialty drugs.9 Claims data from the OCM show that drug spending now makes up more than half of the total cost of care. Analyses of private sectorFinancialFinancial payerFinancial data also show SummarySummary significantSummary variation in the use Financialof specialty drugs forFinancial Summary treating cancer, caused Summary by the lack of refined diagnoses, rapidly changing therapies, lack of adherence to pathways and perverse financial incentives. UseUse this thisUse section section this section to to give give to a a briefgive brief a summary summarybrief summary of of your your of financials, financials, your financials, highlighting highlighting highlighting important important important points. points. points. Some Some of Someof the the of the Use this section to give a briefUse this summary section of to your give financials, a brief summary highlighting of your important financials, points. highlighting Some of important the points. Some of the Key Principles for Redesigning samplethesample sampleOncology text text in in textthis this indocument document this Care document indicates indicates Model indicates the the name name the ofname of the the style ofstyle the applied, applied,style applied, so so that that so you you that can can you easily easily can applyeasily apply the applythe same same the same sample text in this documentsample indicates text in the this name document of theformattingformatting indicates styleformatting applied, again. again.the name so again. that of youthe stylecan easily applied, apply so thethat same you can easily apply the same As this Work Group developed its recommendations, the members identified five key principles formatting again. formatting again. that they believed should guide the redesign of the Oncology Care Model. These principles, as

articulated in detail in this paper, align with•• theForFor •broader example, example,For example, this setthis is ofis thisthe the principles List isList the Bullet Bullet List Bulletstyle. style.described style. in the HCP 10 LAN• Roadmap:For example, this is the• ListFor Bullet example, style. this is the List Bullet style. •• HereHere• is isHere another another is another sentence sentence sentence formatted formatted formatted in in List List inBullet Bullet List Bulletstyle. style. style. • Here is another sentence• Hereformatted is another in List sentence Bullet style. formatted in List Bullet style. (1) Focus on Episodes with the most opportunity for care redesign, quality improvement and cost reduction; (2) Use existing, payer-agnostic sets of clinical pathways; (3) Clinicians should be responsible for only the care patterns they can control, but should have full accountability within those pathways; (4) Overlap policy should ensure appropriate opportunity within each model; and (5) Model evaluation is paramount to enable informed payment policy decisions.

1st Principle: Focus on Episodes with the most opportunity for care redesign Payers should strive to create comprehensive oncology care models that hold providers accountable for appropriate symptom management, behavioral health needs, palliative and end-of-life care, and survivorship.11 In 2016, breast, prostate, and lung cancer had the highest incidence rates. These cancers, as well as colorectal cancer, had the highest mortality rates.12 More importantly, for the Medicare program, these types of cancers had the highest number of episodes, mitigating concerns about the nature of the risk associated with small sample sizes.13

8Prasad V, De Jesús K, Mailankody S, The high price of anticancer drugs: origins, implications, barriers, solutions. •• ForFor• example, example,For example, this this is is thisthe the List isList the Bullet Bullet List Bulletstyle. style. style. Nat. Rev. Clin. Oncol. 2017 Jun:14(6):381-390. 9 • For example, this is the• ListFor Bullet example, style. this is the List Bullet style. Fitch, Kathryn, Pelizzari, Pamela M., and Pyenson, Bruce.•• Here“CostHere• is isDriversHere another another is ofanother sentence Cancersentence sentence Care,” formatted formatted Milliman, formatted in in List List April inBullet Bullet List 2016. Bulletstyle. style. http://www. style. milliman.com/uploadedFiles/insight/2016/trends-in-cancer-care.pdf, accessed May 15, 2019. 10 • Here is another sentence• Hereformatted is another in List sentence Bullet style. formatted in List Bullet style. Health Care Payment Learning and Action Network, Roadmap•• ForFor• example, example, forFor Driving example, this this High is is thisthe the Performance List isList the Bullet Bullet List Bulletstyle. style.in Alternative style. Payment Models (April• 2019).For example, Retrieved this on is theMay• List 15,For Bullet 2019,example, style. from this https://hcp-lan.org/workproducts/roadmap-final.pdf. is the List Bullet style. 11CMS Alliance to Modernize Healthcare. Specialty Payment•• HereHere Model• is isHere another anotherOpportunities is another sentence sentence sentence Assessment formatted formatted formatted andin in List List Design: inBullet Bullet List Bulletstyle. style. style. Environment• Here is Scan another for Oncologysentence• Here formatted(July is 23, another 2013). in List sentence Bullet style. formatted in List Bullet style. 12American Cancer Society, Cancer Facts & Figures 2019. Retrieved on November 13, 2019, from https://www.cancer.org/ research/cancer-facts-statistics/all-cancer-facts-figures/cancer-facts-figures-2019.html ViewView and andView edit edit and this this edit document document this document in in Word Word in on Wordon your your on computer, computer, your computer, tablet, tablet, tablet,or or phone. phone. or phone. View and edit this documentView in and Word edit on this your document computer, in tablet,Word on or yourphone. computer, tablet, or phone. TEL:TEL: 855.395.6171 855.395.6171TEL: 855.395.6171 | | EMAIL: EMAIL: | [email protected] EMAIL:[email protected] [email protected] PowerofRemedy.comPowerofRemedy.comPowerofRemedy.com TEL: 855.395.6171 | EMAIL:TEL: [email protected] 855.395.6171 | EMAIL: [email protected] Connecticut Connecticut800 Connecticut Avenue, Avenue, Avenue,Floor Floor 3 3 East FloorEast Norwalk, Norwalk, PowerofRemedy.com3 East Norwalk, CT CT 06854 06854 CT 06854 PowerofRemedy.com 800 Connecticut Avenue, Floor 3800 East Connecticut Norwalk, CT Avenue, 06854 Floor 3 East Norwalk, CT 06854

Redesigning the Oncology Care Model

The next Oncology Care Model should require that practices participate in these four Clinical Episode types, ensuring that the model coversTHISTHIS IS ISTHIS theTHE THE IS TITLEmost TITLE THE OF TITLE OFprevalent THE THE OF DOCUMENT DOCUMENT THE DOCUMENTtreatable, | | REMEDY REMEDY and | REMEDY costly PARTNERS PARTNERS PARTNERScancers. | | MAY MAY | 2019 2019 MAY 2019 PAGE:PAGE: PAGE:4 4 4 THIS IS THE TITLE OF THETHIS DOCUMENT IS THE TITLE | OFREMEDY THE DOCUMENT PARTNERS | | REMEDY MAY 2019 PARTNERS | MAYPAGE: 2019 4 PAGE: 4

Requiring participation in these four Clinical Episode types will not disadvantage oncology practices, which rarely focus on only one type of cancer. Payers need to be bold in their attempt to influence the practice’s approach to care delivery. The global approach of an oncology practice to the care of a patient should not differ FinancialbasedFinancialFinancial on the type of SummarycancerSummary Summary that the patient is afflicted Financialwith. Although the FinancialmodelSummary should encourage Summary customization of strategies based on differences in that cancer cohort, this standardized but personalized approach should prevent the perverse UseUse this thisUse section section this section to to give give to a a briefgive brief a summary summarybrief summary of of your your of financials, financials, your financials, highlighting highlighting highlighting important important important points. points. points. Some Some of Someof the the of the incentives to target care redesign to a subset of the practice’s patients. Moreover, Medicare should Use this section to give a briefUse this summary section of to your give financials, a briefsamplesample summary samplehighlighting text text in inof textthis thisyour in document importantdocument financials,this document indicates points.indicates highlighting indicates Some the the name ofname important the ofname of the the points. style ofstyle the applied, applied,style Some applied, of so so the that that so you you that can can you easily easily can applyeasily apply the applythe same same the same proffer a model that is adaptable and attractive to the needs of commercial payers. Focusing on sample text in this documentsample indicates text in the this name document of theformattingformatting indicates styleformatting applied, again. again.the name so again. that of youthe stylecan easily applied, apply so thethat same you can easily apply the same these four Clinical Episode types would support a multi-payer model; practices will typically formatting again. formatting again. contract with a commercial payer for lung, prostate, colorectal and breast cancers.

•• ForFor• example, example,For example, this this is is thisthe the List isList the Bullet Bullet List Bulletstyle. style. style. Payers,• For includingexample, this Medicare, is the• ListFor Bullet example, need style. to this ensure is the List that Bullet clinicians style. can apply and implement the Episode •• HereHere• is isHere another another is another sentence sentence sentence formatted formatted formatted in in List List inBullet Bullet List Bulletstyle. style. style. definitions in a tumor-specific way. To achieve this, however, requires a sophisticated and detailed • Here is another sentence• Hereformatted is another in List sentence Bullet style. formatted in List Bullet style. financial methodology. The clinical pathways and metrics for each cancer will be different, with concomitant financial implications. Translating oncology clinical pathways into reporting metrics and episode budgets is particularly difficult due to the staging issues associated with each type of cancer. But these issues are necessary to confront so that participating physicians do not have to; simplicity in the care model requires sophistication in the financial model.

2nd Principle: Use existing, payer-agnostic sets of clinical pathways Clinical pathways are decision-support tools used by either clinicians or health plans to ensure that care delivery is in accordance with evidence-based medicine. These tools set forth decision algorithms that are derived from the scholarly-evidence for care in that practice area. For oncology, clinical pathways intend to direct oncologists as to the course of treatment that is cost- effective, most efficacious, and least toxic. Pathways are tailored to individual patients based on diagnostic tests, the stage of cancer, and any comorbidities. Importantly, these tools allow for refinement to the treatment in the event that the patient is not responding to a set of physician- or patient-administered drugs.

Building on previous oncology initiatives by national payers, the next Oncology Care Model should reward practices for (and hold them•• responsible ForFor• example, example,For example, for)this this is isfollowing thisthe the List isList the Bullet Bullet List known Bulletstyle. style. evidence-basedstyle. • For example,14 this is the• ListFor Bullet example, style. this is the List Bullet style. pathways. Medicare should first, however,•• identify—withHereHere• is isHere another another is another sentence sentencethe sentenceadvice formatted formatted offormatted commercial in in List List inBullet Bullet List Bulletstyle. style.payers, style. practices,• Here is and another patients—the sentence• Hereformatted pathways is another in List sentence Bulletthat will style. formatted underpin in List the Bullet model, style. regardless of the payer. •• ForFor• example, example,For example, this this is is thisthe the List isList the Bullet Bullet List Bulletstyle. style. style. • For example, this is the• ListFor Bullet example, style. this is the List Bullet style. 13Abt Associates. Oncology Care Model: Evaluation of the•• OncologyHereHere• is isHere another another Care is another Model: sentence sentence Performancesentence formatted formatted formatted Periodin in List List inOneBullet Bullet List (December Bulletstyle. style. style. 2018). Retrieved• Here on is Novemberanother sentence 13,• 2019, Hereformatted from https://innovation.cms.gov/Files/reports/ocm-secondannualeval-pp1.pdf is another in List sentence Bullet style. formatted in List Bullet style. 14 Feinberg BA, Lang J, Grzegorczyk, et al. Implementation of cancer clinical care pathways. J. Oncol. Prac. 2012;8(3 Suppl):e38s-43s. ViewView and andView edit edit and this this edit document document this document in in Word Word in on Wordon your your on computer, computer, your computer, tablet, tablet, tablet,or or phone. phone. or phone. View and edit this documentView in and Word edit on this your document computer, in tablet,Word on or yourphone. computer, tablet, or phone. TEL:TEL: 855.395.6171 855.395.6171TEL: 855.395.6171 | | EMAIL: EMAIL: | [email protected] EMAIL:[email protected] [email protected] PowerofRemedy.comPowerofRemedy.comPowerofRemedy.com TEL: 855.395.6171 | EMAIL:TEL: [email protected] 855.395.6171 | EMAIL: [email protected] Connecticut Connecticut800 Connecticut Avenue, Avenue, Avenue,Floor Floor 3 3 East FloorEast Norwalk, Norwalk, PowerofRemedy.com3 East Norwalk, CT CT 06854 06854 CT 06854 PowerofRemedy.com 800 Connecticut Avenue, Floor 3800 East Connecticut Norwalk, CT Avenue, 06854 Floor 3 East Norwalk, CT 06854

Redesigning the Oncology Care Model

Those developing oncology-specific clinical pathways differ in their approach to defining, implementing, and enforcing them. THISTHIS IS ISTHIS THE THE IS TITLE TITLE THE OF TITLEOF THE THE OF DOCUMENT DOCUMENT THE DOCUMENT | | REMEDY REMEDY | REMEDY PARTNERS PARTNERS PARTNERS | | MAY MAY | 2019 2019 MAY 2019 PAGE:PAGE: PAGE:4 4 4 THIS IS THE TITLE OF THETHIS DOCUMENT IS THE TITLE | OFREMEDY THE DOCUMENT PARTNERS | | REMEDY MAY 2019 PARTNERS | MAYPAGE: 2019 4 PAGE: 4

This Work Group believes that the clinical pathways should define the financial accountability of the participating practices. It is therefore imperative that Medicare and other payers agree on the clinical pathways that will underlie the model. Given the amount of work and credibility that Medicare has afforded to the National ComprehensiveFinancialFinancialFinancial Care Network, SummarySummary Summary we believe that the clinical Financialpathways should deriveFinancial Summary from the work alreadySummary completed with the NCCN. In fact, OCM incorporates NCCN guidelines. Our recommendation would be to make the NCCN guidelines—or pathways UseUse this thisUse section section this section to to give give to a a briefgive brief a summary summarybrief summary of of your your of financials, financials, your financials, highlighting highlighting highlighting important important important points. points. points. Some Some of Someof the the of the constructs based on the NCCN guidelines—more explicit as a component of quality and payment Use this section to give a briefUse this summary section of to your give financials, a briefsamplesample summary samplehighlighting text text in inof textthis thisyour in document importantdocument financials,this document indicates points.indicates highlighting indicates Some the the name ofname important the ofname of the the points. style ofstyle the applied, applied,style Some applied, of so so the that that so you you that can can you easily easily can applyeasily apply the applythe same same the same in Medicare’s next oncology payment model. sample text in this documentsample indicates text in the this name document of theformattingformatting indicates styleformatting applied, again. again.the name so again. that of youthe stylecan easily applied, apply so thethat same you can easily apply the same formatting again. formatting again. The foundation of the next oncology payment model should rest on these widely-accepted

guidelines. Using NCCN guidelines is the surest•• ForFor •way example, example,For to example, support this this is is thisthe the the List isList the difficultBullet Bullet List Bulletstyle. style. process style. of translating 15 clinical• For practiceexample, this into is themetrics• ListFor Bullet example, and style. budgets. this is the List This Bullet is importantstyle. to consumers, to employers, and •• • to payers. Consumers want to receive appropriate HereHere is careisHere another another isand another sentence sentence survive. sentence formatted formatted16 And formatted in employersin List List inBullet Bullet List Bulletstyle. style. reinforce style. • Here is another sentence• Hereformatted is another in List sentence Bullet style. formatted in List Bullet style. these needs; they are concerned principally with whether their employees are receiving evidence- based-guideline-driven care.17 Clinical guidelines support employers’ aspirations for evolved versions of a “Center of Excellence,” emphasizing diagnosis as well as treatment of a given condition.

Above all, this requires measures derived from guidelines that allow employers, clinicians, and patients to meaningfully compare providers.18 And it requires data generated by the physicians or observed in Medicare claims. In an ideal model, the information would be available in the claims process, but the next oncology payment model may not be able to evaluate clinicians properly without direct access to medical records. Nevertheless, consistent measurement based principally on Medicare claims or existing registries could reduce the regulatory burden on the participating clinicians. Medicare and other payers should aspire to set forth metrics that—if a clinician demonstrates conformity with the relevant guideline—eliminate duplicative or unnecessary documentation and reporting.

15 • Here is another sentence• Hereformatted is another in List sentence Bullet style. formatted in List Bullet style. The NCCN guidelines are the most widely accepted clinical•• ForFor• practice example, example,For example, guidelines this this is is thisthe the in List isList use, the Bullet Bullet thoughList Bulletstyle. style. they style. are not without controversy.• For example, this is the• ListFor Bullet example, style. this is the List Bullet style. 16 Berry LL & Mate KS. Essentials for improving service •quality• HereHere• in is iscancerHere another another is care. another sentence sentence Healthcare sentence formatted formatted 2016;4:312-316. formatted in in List List inBullet Bullet List Bulletstyle. style. style. 17 National• Here Business is another Group sentence on• Health. Hereformatted is An another Employer’s in List sentence Bullet Guide style. formatted to Cancer in ListTreatment Bullet style. & Prevention (2013). Retrieved on May 15, 2019, from https://www.businessgrouphealth.org/pub/?id=f314ce36-2354-d714-5167-94d96ac431fc. 18 Clough JD and Kamal AH. Oncology Care Model. J.ViewView Oncol. and andView Prac. edit edit and this this2015;11(4):319-321.` edit document document this document in in Word Word in on Wordon your your on computer, computer, your computer, tablet, tablet, tablet,or or phone. phone. or phone. View and edit this documentView in and Word edit on this your document computer, in tablet,Word on or yourphone. computer, tablet, or phone. TEL:TEL: 855.395.6171 855.395.6171TEL: 855.395.6171 | | EMAIL: EMAIL: | [email protected] EMAIL:[email protected] [email protected] PowerofRemedy.comPowerofRemedy.comPowerofRemedy.com TEL: 855.395.6171 | EMAIL:TEL: [email protected] 855.395.6171 | EMAIL: [email protected] Connecticut Connecticut800 Connecticut Avenue, Avenue, Avenue,Floor Floor 3 3 East FloorEast Norwalk, Norwalk, PowerofRemedy.com3 East Norwalk, CT CT 06854 06854 CT 06854 PowerofRemedy.com 800 Connecticut Avenue, Floor 3800 East Connecticut Norwalk, CT Avenue, 06854 Floor 3 East Norwalk, CT 06854

Redesigning the Oncology Care Model

3rd Principle: Clinicians should only be responsible for the care patterns they control Many oncology payment initiatives focusTHIS THISon achievingIS ISTHIS THE THE IS TITLE TITLE THE savingsOF TITLEOF THE THE OF DOCUMENT DOCUMENT THEthrough DOCUMENT the | | REMEDY following REMEDY | REMEDY PARTNERS PARTNERS and PARTNERS so should | | MAY MAY | 2019 2019 MAY 2019 PAGE:PAGE: PAGE:4 4 4

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(1) Implementation of cost-effective drug regimens, advanced by clinical pathways; and (2) Reduction in the utilization of health care services due to treatment toxicity, progressive symptoms of malignancy,Financial Financialor exacerbationsFinancial of Summary Summarychronic Summary underlying comorbid Financialmedical conditions,Financial Summary in an effort to improve Summary patient outcomes. UseUse this thisUse section section this section to to give give to a a briefgive brief a summary summarybrief summary of of your your of financials, financials, your financials, highlighting highlighting highlighting important important important points. points. points. Some Some of Someof the the of the Setting financial targets is an integral part of payment reform, which should transfer to the Use this section to give a briefUse this summary section of to your give financials, a briefsamplesample summary samplehighlighting text text in inof textthis thisyour in document importantdocument financials,this document indicates points.indicates highlighting indicates Some the the name ofname important the ofname of the the points. style ofstyle the applied, applied,style Some applied, of so so the that that so you you that can can you easily easily can applyeasily apply the applythe same same the same provider the right technical risk but not the insurance risk associated with the patient population. sample text in this documentsample indicates text in the this name document of theformattingformatting indicates styleformatting applied, again. again.the name so again. that of youthe stylecan easily applied, apply so thethat same you can easily apply the same Practices in the next Oncology Care Model should be responsible for risk-adjusted costs of care, formatting again. formatting again. but not exposed to exogenous risk.

•• ForFor• example, example,For example, this this is is thisthe the List isList the Bullet Bullet List Bulletstyle. style. style. Oncology• For example, practices this is need the• ListFor reliable, Bullet example, style. transparent this is the List benchmarksBullet style. in order to make upfront capital •• HereHere• is isHere another another is another sentence sentence sentence formatted formatted formatted in in List List inBullet Bullet List Bulletstyle. style. style. investments in care redesign. Payers in the next Oncology Care Model should therefore establish • Here is another sentence• Hereformatted is another in List sentence Bullet style. formatted in List Bullet style. realistic benchmarks that accommodate variability based on clinical characteristics and patient needs.19 This Work Group recommends that payers set Clinical Episode pricing derived from the evidence-based pathways defined under the 2nd Principle (Establish “payer-agnostic clinical pathways”). This will remove risks associated with an undesirable case mix associated with higher intrinsic cost. This is essential in order to articulate a program design that adapts to changes in oncology practice and can be understood by clinicians. That said, the choice of pathways should be informed by advanced diagnostics that help refine the disease state of the patient.

This Work Group recommends that payers under the next Oncology Care Model hold providers accountable to clinical pathways but not set benchmarks that include drug pricing, either for physician- or patient-administered oncology drugs. Oncology practices don’t control the price of drugs, which varies between payers, even within a given type of cancer.20 However, practices are

19Kline RM, et al., Design Challenges of an Episode-based Payment Model in Oncology. J. Oncol. Prac. 2017; 13(7):e632-e645. 20 See Abt Associates. First Annual Report from the Evaluation of the Oncology Care Model: Baseline Period (February 2018). Retrieved on May 15, 2019, from https://downloads.cms.gov/files/cmmi/ocm-baselinereport.pdf. Physicians should be compensated for managing the care they deliver in all its complexity while containing the costs they can effectively control. •• ForFor• example, example,For example, this this is is thisthe the List isList the Bullet Bullet List Bulletstyle. style. style. But this is not the oncology health care delivery system that exists today. By statute, Medicare pays physicians the average • For example, this is the• ListFor Bullet example, style. this is the List Bullet style. sales price, plus 6 percent, for most drugs and biologics•• coveredHereHere• is is Hereby another another Part is anotherB. sentence sentencePhysician sentence formatted formatted offices formatted capture in in List List in Bullet Bulletnearly List Bulletstyle. style.60% style.of the over $20 billion in Medicare (and patient) spending on this segment of Part B. Some analysts have credible evidence suggesting • Here is another sentence• Hereformatted is another in List sentence Bullet style. formatted in List Bullet style. that this physician office business model for Part B drugs•• ForcanFor• example, affectexample,For example,selection this this is is thisthe ofthe therapies. List isList the Bullet Bullet List Jacobson Bulletstyle. style. style. M, et al., How Medicare’s payment• For cuts example, for cancer this is chemotherapy the• ListFor Bullet example, drugs style. this changed is the Listpatterns Bullet of style. treatment. Health Affairs 2010;29(7):1391-1399. See also Medicare Payment Advisory Commission, Report to the•• Congress: HereHere• is isHere another Medicareanother is another sentence sentence and thesentence formatted Healthformatted formatted Care in in ListDelivery List inBullet Bullet List System Bulletstyle. style. (Junestyle. 2015) (“Since• Here 6 percent is another of a sentencehigher• priced Hereformatted drug is another generates in List sentence Bullet more style. formatted revenue for in theList providerBullet style. than 6 percent of a lower priced drug, selection of the higher priced drug has the potential to generate more profit, depending on the provider’s acquisition costs for the two drugs”). ViewView and andView edit edit and this this edit document document this document in in Word Word in on Wordon your your on computer, computer, your computer, tablet, tablet, tablet,or or phone. phone. or phone. View and edit this documentView in and Word edit on this your document computer, in tablet,Word on or yourphone. computer, tablet, or phone. TEL:TEL: 855.395.6171 855.395.6171TEL: 855.395.6171 | | EMAIL: EMAIL: | [email protected] EMAIL:[email protected] [email protected] PowerofRemedy.comPowerofRemedy.comPowerofRemedy.com TEL: 855.395.6171 | EMAIL:TEL: [email protected] 855.395.6171 | EMAIL: [email protected] Connecticut Connecticut800 Connecticut Avenue, Avenue, Avenue,Floor Floor 3 3 East FloorEast Norwalk, Norwalk, PowerofRemedy.com3 East Norwalk, CT CT 06854 06854 CT 06854 PowerofRemedy.com 800 Connecticut Avenue, Floor 3800 East Connecticut Norwalk, CT Avenue, 06854 Floor 3 East Norwalk, CT 06854

Redesigning the Oncology Care Model

and should be responsible for choosing the lower cost therapy within the choice set imposed by a payer. Practices are beholden to the attributesTHISTHIS IS ISTHIS THE THE of IS TITLE theirTITLE THE OF TITLE OFpatient THE THE OF DOCUMENT DOCUMENT THE panel, DOCUMENT including | | REMEDY REMEDY | REMEDY the PARTNERS PARTNERS incidence PARTNERS | | MAY MAY | 2019 2019 MAY 2019 PAGE:PAGE: PAGE:4 4 4 THISand IStype THE ofTITLE cancer OF THE afflictingTHIS DOCUMENT IS THE TITLEthem, | OFREMEDY and THE DOCUMENTcan PARTNERS control | |the REMEDY MAY utilization 2019 PARTNERS of drugs | MAYPAGE: and, 2019 4in particular, thePAGE: 4

utilization of the right drug for the right patient. As such, payers should consider segmenting the financial responsibilities for the total costs of cancer care. Instead of a binary option of risk/no-risk for oncology drugs, payers could allow practices to accept downside risk for some components and upside risk for others (i.e.FinancialFinancial PartFinancial A and Part B Summary Summaryservices Summary for downside risk; Part B Financialdrugs and Part D forFinancial Summary upside only). Summary UseUse this thisUse section section this section to to give give to a a briefgive brief a summary summarybrief summary of of your your of financials, financials, your financials, highlighting highlighting highlighting important important important points. points. points. Some Some of Someof the the of the Further, the inability of many practices to manage downside risk has reduced the willingness to Use this section to give a briefUse this summary section of to your give financials, a briefsamplesample summary samplehighlighting text text in inof textthis thisyour in document importantdocument financials,this document indicates points.indicates highlighting indicates Some the the name ofname important the ofname of the the points. style ofstyle the applied, applied,style Some applied, of so so the that that so you you that can can you easily easily can applyeasily apply the applythe same same the same participate in many double-sided risk models, and that fear has even led larger medical groups sample text in this documentsample indicates text in the this name document of theformattingformatting indicates styleformatting applied, again. again.the name so again. that of youthe stylecan easily applied, apply so thethat same you can easily apply the same and health systems to bow out of the Medicare ACO program. Organizations that can facilitate formatting again. formatting again. clinical data integration, information sharing and financial risk mitigation, such as the convener-

awardees in the Medicare Bundled Payment•• forForFor •Care example, example,For Improvement example, this this is is thisthe the List isList the program,Bullet Bullet List Bulletstyle. style. havestyle. proven to be• effectiveFor example, at helping this is the• practices ListFor Bullet example, style. overcome this is the the List Bulletfear of style. downside risk, and we recommend that •• • Medicare allow convener-awardees in the next HereHere OCM. is isHere another another is another sentence sentence sentence formatted formatted formatted in in List List inBullet Bullet List Bulletstyle. style. style. • Here is another sentence• Hereformatted is another in List sentence Bullet style. formatted in List Bullet style.

4th Principle: Overlap policy should ensure appropriate opportunity within each model The Innovation Center recently proposed the Radiation Oncology (RO) model to test the value of a prospective episode-based payment model.21 This model will overlap with the Oncology Care Model; the extent of that overlap depends on the type of OCM Clinical Episode.22 According to the RO proposed rule, if an RO episode overlaps with an OCM episode, each will be initiated and reconciled.23 The current overlap policy allows both models to co-exist, which CMMI has noted in other contexts is “likely to result in compounded efficiencies and clinical integration.”24 We encourage CMS to maintain this overlap policy in the next version of the Oncology Care Model. Concurrent OCM and RO episodes will encourage different oncologists—furnishing different modalities of cancer treatment—to improve the quality of care and retain financial accountability for the cancer therapy services that each oncologist controls. And it would create an incentive for participants in the next OCM to work closely with providers of radiation therapy services to best manage the care of patients.

CMS correctly notes in the RO proposed rule that the overlap policy should avoid double counting 25 savings and losses. OCM participants will not receive the benefit of the withhold or the RO discount; •• ForFor• example, example,For example, this this is is thisthe the List isList the Bullet Bullet List Bulletstyle. style. style. 21 • For example, this is the• ListFor Bullet example, style. this is the List Bullet style. 84 Fed. Reg. 34478 (July 18, 2019). •• HereHere• is isHere another another is another sentence sentence sentence formatted formatted formatted in in List List inBullet Bullet List Bulletstyle. style. style. 22Abt Associates. First Annual Report from the Evaluation of the Oncology Care Model: Baseline Period (February 2018). • Here is another sentence• Hereformatted is another in List sentence Bullet style. formatted in List Bullet style. Retrieved on May 15, 2019, from https://downloads.cms.gov/files/cmmi/ocm-baselinereport.pdf.•• ForFor• example, example,For example, this this is is thisthe the List isList the Bullet Bullet List Bulletstyle. style. style.84 Fed. Reg. 34534-34535. 23 84• Fed.For Reg. example, 34534-34535 this is the• (JulyListFor Bullet 18,example, 2019) style. this (“If is an the entire List BulletRO Model style. episode (90-days of RT services) occurs completely during a 6-month OCM episode, then the associated RO•• paymentsHereHere• is isHere another anotherfor isRT another services sentence sentence sentence would formatted formatted be formatted included in in List List in Bullet inBullet List the Bulletstyle.OCM style. episode”). style. 24 80• Fed.Here Reg. is another 73393 (Nov.sentence •24, Hereformatted2015) is (Medicareanother in List sentence BulletProgram; style. formatted Comprehensive in List Bullet Care style.for Joint Replacement Payment Model for Acute Care Hospitals Furnishing Lower Extremity Joint Replacement Services; Final Rule). 2584 Fed. Reg. 34535 (July 18, 2019). ViewView and andView edit edit and this this edit document document this document in in Word Word in on Wordon your your on computer, computer, your computer, tablet, tablet, tablet,or or phone. phone. or phone. View and edit this documentView in and Word edit on this your document computer, in tablet,Word on or yourphone. computer, tablet, or phone. TEL:TEL: 855.395.6171 855.395.6171TEL: 855.395.6171 | | EMAIL: EMAIL: | [email protected] EMAIL:[email protected] [email protected] PowerofRemedy.comPowerofRemedy.comPowerofRemedy.com TEL: 855.395.6171 | EMAIL:TEL: [email protected] 855.395.6171 | EMAIL: [email protected] Connecticut Connecticut800 Connecticut Avenue, Avenue, Avenue,Floor Floor 3 3 East FloorEast Norwalk, Norwalk, PowerofRemedy.com3 East Norwalk, CT CT 06854 06854 CT 06854 PowerofRemedy.com 800 Connecticut Avenue, Floor 3800 East Connecticut Norwalk, CT Avenue, 06854 Floor 3 East Norwalk, CT 06854

Redesigning the Oncology Care Model

those are inherent to the finances of the RO model. But CMS should apply this policy equally to the OCM Target Price calculation to avoid skewingTHISTHIS IS ISoncologists’THIS THE THE IS TITLE TITLE THE OF TITLEOF financialTHE THE OF DOCUMENT DOCUMENT THE DOCUMENT incentives. | | REMEDY REMEDY | Instead REMEDY PARTNERS PARTNERS ofPARTNERS counting | | MAY MAY | 2019 2019 MAY 2019 PAGE:PAGE: PAGE:4 4 4 THISthe radiation IS THE TITLE therapy OF THETHIS DOCUMENT services IS THE TITLE in | the OFREMEDY OCM THE DOCUMENT baselinePARTNERS period, | | REMEDY MAY CMS 2019 PARTNERS should impute | MAYPAGE: the 2019 4 RO baseline PAGE: 4

price to the OCM Target Price calculation. This will remove an arbitrage opportunity created by the difference between the sum of radiation therapy services in the OCM baseline period and the RO baseline price imputed in the OCM Performance Period. This policy will focus OCM participants on the clinical rather than financial justificationFinancialFinancialFinancial for a particular SummarySummaryradiation Summary therapy provider or modality. Financial Financial Summary Summary 5th Principle: Rigorous model evaluationUseUse this thisUse issection section this paramount section to to give give to a a briefgive brief a summary summarybrief summary of of your your of financials, financials, your financials, highlighting highlighting highlighting important important important points. points. points. Some Some of Someof the the of the UseThe this Innovation section to give Center a briefUse this summary within section the of to your give Medicare financials, a briefsamplesample summary program, samplehighlighting text text in inof textthis thisyour established in document importantdocument financials,this document indicates points.indicates highlighting by indicates theSome the the Patient name ofname important the ofname of Protectionthe the points. style ofstyle the applied, applied,style Some applied, of so so the that that so you you that can can you easily easily can applyeasily apply the applythe same same the same sampleand Affordable text in this document Caresample Act indicates oftext 2010, in the this name wasdocument ofintended theformattingformatting indicates styleformatting applied, by again. again.the Congress name so again. that of youthe to stylecantest easily applied, the applymerits so thethat ofsame you new can approacheseasily apply the same formatting again. formatting again. to paying for health care. To date, most of the payment reforms sponsored by the Innovation Center have been voluntary, including the Oncology Care Model. That’s an important principle because it allows practices that are willing •to• takeForFor• example, example, financialFor example, this this is isaccountability thisthe the List isList the Bullet Bullet List Bulletstyle. style. for style. their patients to do • For example, this is the• ListFor Bullet example, style. this is the List Bullet style. so willingly. •• HereHere• is isHere another another is another sentence sentence sentence formatted formatted formatted in in List List inBullet Bullet List Bulletstyle. style. style. • Here is another sentence• Hereformatted is another in List sentence Bullet style. formatted in List Bullet style.

However, models inviting—as opposed to compelling—participation can introduce biases into the evaluation, muddying the conclusions about the effectiveness of the model. In health policy, an “observational study”—or voluntary model—would draw in a cohort of physicians that is fundamentally different than those declining such an opportunity.26 This creates issues for the evaluators of payment reform, and, as a result, can create an ongoing barrier to the adoption of APMs by failing to more definitively draw conclusions about their effect.

The Innovation Center should therefore use a geographically-defined mandatory model, run concurrently with a voluntary pilot, as that will allow rigorous evaluation of the next Oncology Care Model. The Medicare program has a strong interest in creating sufficient, unbiased scale in the next model to observe model impact and draw conclusions about payment policy.27 And the ability for convener-awardees to participate in the next OCM could overcome the potential resistance of oncologists that are included in the randomized trial.

•• ForFor• example, example,For example, this this is is thisthe the List isList the Bullet Bullet List Bulletstyle. style. style. • For example, this is the• ListFor Bullet example, style. this is the List Bullet style. •• HereHere• is isHere another another is another sentence sentence sentence formatted formatted formatted in in List List inBullet Bullet List Bulletstyle. style. style. • Here is another sentence• Hereformatted is another in List sentence Bullet style. formatted in List Bullet style. •• ForFor• example, example,For example, this this is is thisthe the List isList the Bullet Bullet List Bulletstyle. style. style. • For example, this is the• ListFor Bullet example, style. this is the List Bullet style. •• HereHere• is isHere another another is another sentence sentence sentence formatted formatted formatted in in List List inBullet Bullet List Bulletstyle. style. style. 26 Newhouse• Here is JP another & Normand sentence •SLT, Hereformatted Health is another Policy in List Trials. sentence Bullet N. style.Engl. formatted J. Med. in 2017; List Bullet 376:2160-2167. style. 27Duke-Margolis Center for Health Policy. Exploring approaches for value-based reimbursement of oncology therapies (October 3, 2017). ViewView and andView edit edit and this this edit document document this document in in Word Word in on Wordon your your on computer, computer, your computer, tablet, tablet, tablet,or or phone. phone. or phone. View and edit this documentView in and Word edit on this your document computer, in tablet,Word on or yourphone. computer, tablet, or phone. TEL:TEL: 855.395.6171 855.395.6171TEL: 855.395.6171 | | EMAIL: EMAIL: | [email protected] EMAIL:[email protected] [email protected] PowerofRemedy.comPowerofRemedy.comPowerofRemedy.com TEL: 855.395.6171 | EMAIL:TEL: [email protected] 855.395.6171 | EMAIL: [email protected] Connecticut Connecticut800 Connecticut Avenue, Avenue, Avenue,Floor Floor 3 3 East FloorEast Norwalk, Norwalk, PowerofRemedy.com3 East Norwalk, CT CT 06854 06854 CT 06854 PowerofRemedy.com 800 Connecticut Avenue, Floor 3800 East Connecticut Norwalk, CT Avenue, 06854 Floor 3 East Norwalk, CT 06854

Redesigning the Oncology Care Model

Conclusion The Oncology Care Model is a bold experimentTHISTHIS IS ISTHIS THE fromTHE IS TITLE TITLE THE the OF TITLEOF Innovation THE THE OF DOCUMENT DOCUMENT THE DOCUMENT Center. | | REMEDY REMEDYBut | manyREMEDY PARTNERS PARTNERS have PARTNERS | | MAY MAY | 2019 2019 MAY 2019 PAGE:PAGE: PAGE:4 4 4 THISfound IS THEit not TITLE to OFbe THE generalizable,THIS DOCUMENT IS THE TITLE | whether OFREMEDY THE DOCUMENT PARTNERSto non-participating | | REMEDY MAY 2019 PARTNERS practices |or MAY PAGE:payers. 2019 4 Those who PAGE: 4

have succeeded in the model do not understand the source of their success, and recent analyses suggest that the large majority of current participants would experience financial losses if the current model had downside risk. This Work Group recommends that the Innovation Center, in order to ensure proper refinement of theFinancialFinancial model,Financial adopt the fiveSummarySummary PrinciplesSummary outlined in this report Financialas it designs the nextFinancial Summary Oncology Care Model. Summary UseUse this thisUse section section this section to to give give to a a briefgive brief a summary summarybrief summary of of your your of financials, financials, your financials, highlighting highlighting highlighting important important important points. points. points. Some Some of Someof the the of the Payers and oncology practices are continuing to use financial incentives to deliver cost-effective Use this section to give a briefUse this summary section of to your give financials, a briefsamplesample summary samplehighlighting text text in inof textthis thisyour in document importantdocument financials,this document indicates points.indicates highlighting indicates Some the the name ofname important the ofname of the the points. style ofstyle the applied, applied,style Some applied, of so so the that that so you you that can can you easily easily can applyeasily apply the applythe same same the same oncology care. To achieve the desired ends—reduced toxicity, improved outcomes, and moderated sample text in this documentsample indicates text in the this name document of theformattingformatting indicates styleformatting applied, again. again.the name so again. that of youthe stylecan easily applied, apply so thethat same you can easily apply the same cost—it is important for these principles to inform the design of payment reform for oncology formatting again. formatting again. practices to ensure widespread adoption and spread beyond traditional Medicare.