January 2017 Edition Vol.11, Issue 1

2017 Forecast Series—Barry Russo, Chief Executive Officer, The Center for Blood and Cancer Disorders Discusses OCM and MIPS in 2017

OBR talked to Barry Russo, CEO of The Center for Blood and Cancer Disorders, Fort Worth, Texas, and found out how his practice is managing to fulfill the intricate reporting requirements of the Oncology Care Model (OCM) via data capture, along with implementing other requirements associated with payment reform at his practice.

OBR: Tell us about your practice.

BR: We have 20 physicians, including medical oncologists, radiation oncologists, a gynecologic oncologist, and a breast surgeon, as well as 8 advanced practitioners at 9 sites in Fort Worth and surrounding areas.

OBR: What are you involved with right now?

BR: We are closing out 2016 and trying to figure out the reporting for the OCM. [Center for Medicare and Medicaid Services (CMS) Oncology Care Model (OCM) payment program] It’s not a simple process. We think we have a plan but the time commitment for the aggregate data that they have asked for by the end of February is significant, and we are spending an inordinate amount of staff resources and time on figuring it out and trying to report. The first reporting period [performance period] is from when the program started on July 1, 2016, through December 31, 2016, and includes a subset of the aggregate or quality measures OCM-7, OCM-8, OCM-9, OCM-10, and OCM-11. [https://innovation.cms.gov/Files/slides/ocm-performancemethod-slides.pdf]

For each of those measures, they want a numerator and denominator. For example, OCM-7 is a measure of how many patients with prostate cancer we had who were at high risk for recurrence and who received hormonal therapy and radiation, the time frame [of treatment], and whether or not they had metastatic disease. So for this measure we have to determine which patients with prostate cancer fit this category, then determine how many of these are OCM patients as a percentage of our overall population.

And then we go on to the next indicator, OCM-8, which is related to colon cancer, narrow it down to the subgroup in question, and report on that subgroup. If you don’t know anything about running a practice, you might think all that data is [sic] out there, but it’s just not easily accessible and easily obtainable, so we will require manual chart review. We are trying to figure out the most efficient way to get that done.

OBR: Manual chart review does not sound efficient.

BR: No it’s not efficient. As electronic medical records (EMRs) get more sophisticated they’ll be able to capture some of these things in the future, but there may be some questions that there is no way to capture. For example, for the high risk prostate cancer indicator, we have to describe the number of people that have received adjuvant hormonal therapy. Our practice, like many others, does not administer the hormonal therapy; it is administered by a urologist. So we have to find the urologist’s notes or mention of administration of hormonal therapy in the chart.

There are a lot of activities that happen outside of our practice that we have to figure out how to capture. Without a Health Information Exchange (HIE) we have to do a manual chart review.

OBR: Your practice has to hire outside help to gather this [sic] data that may not be accessible within your practice?

BR: That’s exactly right. We can’t just hire temps because they have to have enough clinical knowledge to understand what adjuvant hormonal therapy is and whether the patient is high risk or very high risk. Risk categories aren’t typically captured numerically so a clinical knowledge in oncology is needed. Oncology-specific clinical people are expensive and not easy to find.

OBR: Did participating in COME HOME help you get ready for participation in OCM with respect to data capture?

BR: COME HOME really helped us in the process of care and improvements for how we manage care. It really helped us focus on what do we need to change and what are the fundamental changes we need in the way we provide care so we manage the care process better. I think we are doing a good job with that. I think we are managing the patient’s disease and especially patients with complicated diagnoses better. We have a more multidisciplinary approach to the care, and that’s where COME HOME really helped. Almost all of our COME HOME data came out of the claims system, so we didn’t have any big hurdles on COME HOME data that had to be reported. Many of the things we are looking at in the OCM indicators cannot come out of the claims system so they have to come out of the EMR. And in many cases it might not even be our EMR because it might be a service we don’t even provide.

OBR: How do you foresee improving this problem you are having with data capture?

BR: One, I think the 190 practices in OCM have to identify areas where the return from the data is minimal versus the effort to obtain it. We have to provide feedback to CMS and work with them on making some things simpler. Two, for those things, like adjuvant hormonal therapy in prostate cancer, where the information may be in the charts, just not in standard or reportable fields, I think we have to work with the EMR vendors to provide a platform that is flexible. As more and more programs are developed and more data is [sic] needed, there should be easier changes to the EMR format to account for some of the fields that we’re going to need to add in the future. There should be the ability to change or add a field, or have a specific field become required to be completed before you can move on in the record, or have something like a pop-up to advise you that certain [fields] need to be completed because of some of these programs [require it].

OBR: Do you have an example of data that CMS is asking for that is taking too much time and it’s not benefitting anyone?

BR: OCM-8 is the colon cancer indicator. They want to know the date patients had their surgery. We’re an oncology practice, we didn’t do the surgery. So that means I have to go somewhere and find it. We may not have an operative report in our record but we may have a pathology report. We have to find the pathology report and look for the date of surgery. The question is what difference does that make? I don’t know what impact the date they had surgery would have on outcome and risk assessment.

OBR: Are you concerned that if you leave a field empty when you submit to CMS that one empty field leaves the whole report in jeopardy? Will there be an extension on the submission to allow for an adjustment period?

BR: The registry just opened on the first of January and we haven’t loaded any data. We don’t have enough experience yet to know all the nuances of the registry. For the first reporting period they are only requiring us to put in a numerator and denominator and not have patient-level data. They gave us two months to report, so they recognize that there are some challenges. We have made fundamental changes to the way our practice works, and we’ve made investments in people, process, structures, and IT systems, to better manage patient care in the COME HOME oncology medical home model, so we want OCM to work. We’ve got to have reporting that’s not so laborious that we just can’t manage it. We don’t want to be penalized down the road because we’ve made the fundamental changes that they wanted us to make.

OBR: Can you describe your practice’s participation in the quality payment program?

BR: In addition to being in OCM, we are also in MIPS. [The Merit-based Incentive Payment System (MIPS), which is one of two tracks in the Medicare Quality Payment Program.] This year is the beginning of our reporting period for the 2019 MIPS score. Some of the indicators we’re using for the OCM can be used for MIPS, so we don’t have to duplicate everything. That helps a lot. Our goal is to be in the top quartile of outcome reporting on MIPS. We think we can get there.

OBR: Are you feeling optimistic that everything is moving in a good direction now in terms of OCM and MACRA? [Medicare Access & CHIP (Children’s Health Insurance Program) Reauthorization Act]

BR: We are optimistic that we’ve made investments in the care management process related to oncology medical home that we can see are making a difference in outcome of care for our patients. We are also optimistic that that whole oncology medical home model has pushed us to a much more multidisciplinary and multi-provider approach to patient care that includes not only physician visits, but visits with other providers such as psychologists, a social worker, the chaplain, or a dietician. We’re really optimistic that as we continue to grow we will even have better outcomes in patient care. We’re optimistic that through OCM or MIPS we may have national data to compare to our own data so that we have a story to tell to employers and payers in our own market about our success rate. We are certainly still very nervous about that [sic] data and how we’re going to report. There’s nothing worse than doing a good job, watching the changes in the patient care process, and then not being able to figure out how to report in a way that’s reflective. We’re a little concerned about the Affordable Care Act (ACA) because we don’t know what the future of that is. In our own market I think we are down to only two plans. I know premiums went up, I know patients are struggling. and there’s great confusion and great concern about what the future looks like and how to manage that process. We’re not thinking that’s negative. There are so many things that needed to be changed for the better in the ACA so we’re optimistic that the good parts are kept, the bad parts are managed, and we come out [with a] whole better product. But it’s an unknown, and any time you have an unknown obviously it makes you worry a little bit.

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