CMS Oncology Care First Model RFI Response

In this letter, the Task Force responds to the Center for Medicare and Medicaid Services’ Oncology Care First model Request for Information (RFI). Task Force members have built, operated, and participated in various alternative payment models, including episodes of care models that engage specialists in practice transformation and the Oncology Care Model (OCM). The Task Force letter also encourages CMS to make every effort to make improvements and refinements to existing CMMI models – and to certify and expand those models that are found to successfully improve care and reduce costs – even as second-generation models in the same clinical area enter the design and early testing phase.

Task Force Response Highlights

  1. Practice redesign activities. HCTTF supports the proposed utilization of electronic patient-reported outcomes to both track and drive performance improvement.
  2. Payment methodology. We recommend CMS have educational opportunities, such as webinars, outlining the payment structure in detail and offer additional opportunities for public comment once more detail on the pricing methodology is made available.
  3. Risk arrangements. The additional progression to risk with total cost of care accountability and the new prospective MPP component are enough of a departure from the existing OCM framework that we encourage CMS to allow for all prospective participants to start in the upside-only track for at least three 6-month episode/performance periods before moving to the two-sided risk tracks.
  4. Payer partners. CMS should work closely with payer partners – including commercial payers, state Medicaid agencies, and those payers currently participating in OCM – to develop shared expectations for multi-payer alignment with the goal of reducing administrative burden on providers to participate.


Read the letter