Over the last year, our team at Cota has worked closely with providers and CMS—preparing for the eventual move to value-based payment under MACRA by studying the complexities of the law and building an OCM-specific technology solution on top of our CNA Guided Care™ platform. To address the obvious policy question up front: While the new administration has already planned or implemented sweeping changes across other areas, all indications (including these comments from former CMS head Andy Slavitt) point to Alternative Payment Models (APMs) and value-based payments sticking around for the long haul. In this post, we want to share what we’ve learned so far and officially announce Cota’s new technology solution specifically designed to help providers address the challenges and opportunities during this exciting time in the move value-based healthcare. Jump straight to the Cota OCM product announcement here.
Per MACRA, and solidified in the final rule last October, providers participating in Medicare Part B must choose one of two tracks in the QPP, either the Merit-based Incentive Payment System (MIPS), or an Alternative Payment Model (APM).
The default track, MIPS, is a consolidation of a few programs from the Sustainable Growth Rate (SGR) legislation replaced by MACRA. MIPS assesses clinicians on their performance across four categories and provides a payment adjustment —neutral, positive, or negative—that is based on that performance. MIPS combines familiar, previously-existing programs from the repealed SGR into one program, including the Physician Quality Reporting System (PQRS), Value-Based Modifier (VBM), and Meaningful Use (MU). Essentially, PQRS + VBM + MU + Improvement Activities (new category) = MIPS.
APMs and Advanced APMs are an alternative to MIPS for specific clinical conditions, care episodes, or populations, and provide additional incentives for high-quality and cost-effective care. Advanced APMs are a subset of APMs and practices may earn more payment for taking on risk related to patient outcomes. The Oncology Care Model (OCM) is considered an Advanced APM and to date, 190 practices are signed up to participate in this innovative, and rigorous, value program.
The Quality Payment Programs aim to move all providers to a value-based payment structure by 2019, but performance measurement begins now in 2017. Based on our work with providers, and Cota’s in-house oncology expertise, we’ve identified a few of the challenges practices need to be aware of as they plan for the next year and beyond.
The complexity of practice-reported clinical data needed, particularly on OCM measures, requires more than hiring extra headcount to sift through the EHR. Information about treatments over time, lab reports, and other clinical documentation in a patient’s record isn’t accurately captured by adding extra fields in your EHR, nor will that crucial information be easily located. Most importantly, you’ll lack the crucial real-time insight on patients at risk during that episode of care, leaving you unable to remediate in time.
Likewise, on the IT side, the common solution of dumping information into a data warehouse to make sense of is common response to for OCM reporting. This challenge was best explained in a fall 2016 CIO report by the Scottsdale Institute:
Patrick O’Hare notes that “at Spectrum we do not use the word data warehouse anymore. We have to shift the mindset.” Bill Russell notes that “the enterprise data warehouse is how most other industries aggregated data 5 years ago. Big Data is a trend, not just a buzz word. In healthcare we are going to require analytics for real time surveillance. If we continue to do this with an enterprise data warehouse mindset we will have to hire fifty more people. Instead we need to begin to use machine learning to look for patterns.”
Chief Information Officer Summit Report: Achieving Value-Based Payment Success: Implications for IT and the CIO
Since MACRA’s final rule in October, we’ve noted more than 10 additional changes in calculations and quality measures for OCM alone. These complex calculations and program updates are tedious to track, update within a spreadsheet, and that is without factoring multiple people working on the same report, with the same data, and the likelihood of duplicative work and errors.
If your EHR and data systems aren’t ready for this reporting year, you’re not alone—but it does mean you will need to eventually play catch up in order to report. Retrospective requirements to gather that data require advanced data collection and analysis many practices aren’t willing, or able, to tackle.
For all of the challenges stated above, many providers are realizing they need a technology solution that will help them navigate value-based payment programs like OCM. We’re pleased to announce the public launch of Cota OCM, a comprehensive provider solution for automatically gathering, reporting, and optimizing quality measure performance for OCM.
Having Cota OCM prepares your practice for both the immediate needs of data collection and reporting, and provides guidance and analytics to help maximize future performance incentives and payments. Cota OCM enables practices with powerful technology and expert guidance to make sense of your data so you can:
Our clinical experts and product team have worked closely with one of the largest providers in New Jersey, Regional Care Cancer Associates, to develop a solution that meets the needs of practices participating in OCM.
"Cota OCM is helping Regional Cancer Care Associates (RCCA) to deliver upon many of the critical requirements of the OCM program. Our long-standing relationship with Cota has enabled us to be successful and become a national leader in oncology value-based arrangements."
Michael Ruiz de Somocurcio, VP Payer Strategy and Collaboration, Regional Cancer Care Associates
The move to value-based reimbursement is happening now, and reporting timelines for advanced APMs like OCM are ambitious. In order to succeed and maximize the most benefit possible from the program, practices enrolled in OCM need to be prepared with a solution that can automatically extract the data and documentation already available in the EHR, calculate it, and report it to CMS. Due to the ongoing shifting requirements, practices also need a solution with an experienced team dedicated to OCM who can guide with clinical and technological best practices.