Updates to the Enhancing Oncology Model (EOM): Benefits for Practices

On May 30, 2024, the Centers for Medicare & Medicaid Services (CMS) announced several changes to the program design of its signature oncology-focused value-based payment model - the Enhancing Oncology Model (EOM) - that are very favorable to participating practices. Before we get into what these changes are, let’s first set context through a quick outline of the fundamentals of the program. 

The Enhancing Oncology Model, launched in the summer of 2023, aimed to improve care coordination and reduce total cost of care for Medicare patients with one of several common types of cancer. Participating practices assumed performance and financial accountability for 6-month episodes of care that were defined by the administration of systemic chemotherapy. CMS paid practices $70 per-member per-month (plus an additional $30 PMPM if a patient was dual-eligible and had both Medicaid and Medicare plans) to fund care transformation activities. Additionally, practices assumed mandatory downside risk and had to repay CMS when costs exceeded 98% of their benchmark (involving a complicated calculation of historical performance and peer performance).

How the Oncology Care Model Informed CMS's Enhancing Oncology Model

CMS’s program design choices were informed by experience in its previous value-based payment model, the Oncology Care Model (OCM), which ran from 2016 - 2022. The OCM was CMS’s first foray into testing alternative payment strategies, not just for oncology, but for specialty care medicine in general. While voluntary, nearly 200 practices participated, and at one point, 1 in 4 oncology patients on Medicare were being served by an OCM-participating practice. While providers and practices widely acknowledge that the OCM served as a crucial learning and testing ground for understanding the mechanisms involved in shifting from fee-for-service to value-based care, it proved to be a costly lesson for CMS. The OCM was associated with a more than $300 million net loss to Medicare without meaningful improvements in quality. On review, CMS felt that this loss was related to overspending by way of large monthly payments per member, and little risk-sharing by practices - very few practices ultimately elected to incur downside risk for exceeding spending targets.

These lessons bled over into the EOM - which featured mandatory downside risk, smaller per-member monthly payments, and a higher threshold of total cost of care savings needed to begin shared savings with CMS. However, it was not surprising that practices felt that the terms of engagement were markedly more difficult. With both the OCM and EOM being voluntary models, the trick was always to balance financial viability to CMS with encouraging participation by practices. Last summer, when less than 45 practices signed up to participate in the EOM, with a notable absence of hospital-based practices, it was clear that the balance was not achieved.

CMS Improves EOM: Increased Upfront Payments and New Participation Opportunities

One year into the program, CMS is making critical improvements to the EOM that will likely change the calculus for many practices who were considering participation but ultimately chose not to apply. 

In response to feedback, CMS has made the following updates to their model:

• CMS is reopening the model to new participants. New applicants can begin participating in July 2025.
• Monthly per-member payments are increasing from $70 PBPM to $110 PBPM. For dually eligible beneficiaries, the payment will increase from $100 PBPM to $140 PBPM. This seems to be a recognition of the fact that practices need upfront payments to make the requisite investments in care transformation - and many practices do not have an excess of cash to do this themselves and wait 18 months for reconciliation payments.
• The threshold for repayment back to CMS has become more favorable for practices, as they will now need to repay CMS when costs exceed 100% of their calculated benchmark as opposed to 98% of their benchmark.
• EOM will be extended for another two years for all participants, thus ending in June 2030.
  
  

The Case for EOM Participation

We at Thyme Care believe that these EOM program changes are advantageous to practices and should warrant a reconsideration of participation in the EOM. By choosing to participate now, practices will receive higher upfront payments to invest in care transformation efforts and will face a lower repayment risk threshold. Additionally, while value-based arrangements like the Enhancing Oncology Model are voluntary for now, CMS has strongly hinted that they will become mandatory down the road - so it behooves practices to invest in the infrastructure and learnings required for that future state. Finally, and perhaps most critically, value-based programs like the EOM are fundamentally good for patients. They offer a roadmap for enhanced patient support and comprehensive care, and empower practices to make transformations that can have a meaningful impact on patient experience and outcomes.

While recent changes to the EOM are certainly more favorable for practices, we also understand that they may not be enough. Some practices may find it helpful to partner with a value-based care enablement company that can provide support in standing up the program, engage with patients through electronic patient-reported outcomes, documentation and quality reporting, engage in few but critical pharmacy prescribing interventions that may bend the cost curve, and assume a significant portion of the downside risk. 

Succeeding in the Enhancing Oncology Model with Thyme Care

Thyme Care offers dedicated care support, technology, and expertise to pave the way for success in value-based programs such as the Enhancing Oncology Model. Through robust analytics support, Thyme Care can help oncology groups better understand their potential EOM performance, make recommendations for cost-saving opportunities, and track their performance in real time to proactively identify areas of improvement (EOM Real-Time Performance Tracking). Thyme Care also provides wraparound virtual navigation support for EOM patients to address SDOH barriers, provide emotional support, and proactively manage symptoms through advanced ePRO software and staffing, acting as an extension of the practice’s care team. With nearly 10% of the current EOM population supported by Thyme Care, we have the experience and expertise to enable practice program success.

Organizations that are considering participating in the EOM must submit an application by September 16, 2024. Simply applying for the EOM does not mean you must participate - if selected by CMS, practices can opt out of participation until June 29th 2025. Thyme Care can support practices interested in exploring potential EOM participation by assisting them with the application process, and is also offering a free opportunity analysis for accepted practices to gauge potential practice performance.

Value-based oncology care is here to stay, and practices have the opportunity to be at the forefront of this movement. Thyme Care looks forward to supporting more practices in the Enhancing Oncology Model and empowering their success in value-based care. 

Considering applying to the Enhancing Oncology Model? Reach out here to learn more about how Thyme Care can support.