The Community Oncology Alliance (COA) has submitted comments to the Centers for Medicare and Medicaid Services (CMS) about the proposed rule governing the creation of accountable care organizations (ACOs) under the federal health reform law.
CMS recently published the proposed rule to implement the Medicare Shared Savings Program. The concept as outlined in the Patient Protection and Affordable Health Care Act of 2009 (ACA) requires federal health programs to begin contracting with ACOs starting in January 2012.
ACOs, groups of providers that work together to care for sets of Medicare patients, are an important component of the Affordable Care Act. Meanwhile, approximately half of all U.S. cancer patients are Medicare patients, and that number will continue to increase with the rising incidence of cancer and the aging population.
According to the comment letter, COA has expressed alarm regarding the ACO rule, the premier concern being that cancer care was completely omitted.
“We appreciate and recognize the difficult task of the CMS to operationalize the ACO concept as outlined in health reform law. Unfortunately, the proposed rule published by CMS has totally neglected to address and include cancer care. Not one of the 65 quality measures deals with cancer treatment/care, and it is unclear how oncology practices fit into the ACO framework,” said Ted Okon, executive director of the Community Oncology Alliance. “For this rule, which will fundamentally change our country’s health care delivery system, to not even mention cancer care is incomprehensible.”
According to the comment letter submitted by COA, the quality measures in the Proposed Rule are primary care-based, do not address cancer care and the measures generally have no direct relationship to cost management in the short term.
Because cancer care is not included in the proposed ACO rule, COA has proposed a solution: the establishment of the Patient-Centered Oncology Medical Home (PCOMH) Demonstration, submitted by COA to CMS in March. This Demonstration Project, which builds on the Demonstration already included in the ACA, is a more comprehensive approach involving “harder” endpoints dealing with enhanced quality and lowering costs of care, especially in terms of reducing hospitalizations and decreasing emergency room utilization. This model, already in practice, has been yielding impressive results, including significant decrease in the number of emergency room referrals and the number of hospitalizations of cancer patients, both improving quality and lowering cost.
As part of the suggested demonstration project, COA has proposed the testing of several payment models, including shared savings, episode-of-care, and per beneficiary payment.
“Given the unique and complex nature of cancer care, coupled with the fact that cancer care was left out of the ACO concept, we believe that the Oncology Medical Home is a more realistic way of achieving the underlying ACO goals – care coordination, increased quality, and cost savings,” continued Okon. “In essence, we are focused on enhancing our own ‘home’ as the first step to enhancing the ‘medical neighborhood.’ ”
Community Oncology Alliance (COA)