CMS Public Listening Session: Potential Oncology Care First Model Part 2


>>RON BARKLEY ONCOLOGY BUSINESS CONSULTANT
AND CO CHAIR FOR THE NATIONAL CANCER BUSINESS SUMMIT.
I WANT STOCK EXCHANGE TART BY SAYING THANK YOU VERY MUCH FOR HOLD THIS SESSION
OF STAKEHOLDERS. THE COMMENTS I WANT TO MAKE ARE SOMEWHERE
BETWEEN PAYMENT AND RISK, THEY MIGHT FIT IN TIME, THE OCF AT FIRST READING APPEARS TO
BE A BRILLIANT SUCCESS PLAN, SUCCESS MODEL FOR OCM, AND I THINK THAT’S GREAT, I KNOW
THERE’S A LOT OF QUESTION OUT THERE FOR A WHILE AS TO WHAT HAPPENS WHEN OCM TERMS.
HOWEVER NA MODEL, I WOULD LIKE TO SUGGEST EVEN CHALLENGE YOU TO THINK IN TERMS OF A
BROUGHTER ECONOMIC MODEL AND BY THAT, WHAT I MEAN IS THAT IF YOU LOOK AT THE ECONOMICS
AND THE INCREDIBLE CARE COORDINATION CLINICAL INTEGRATION OPPORTUNITIES IN CANCER CARE FROM
POINT OF DIAGNOSIS, NOT CANCER CARE FROM POINT OF INITIAL CHEMO ADMINISTRATION BECAUSE THE
OCM AND THEN IT LOOKS LIKE THE OCF AS WELL, START IN THE LETTER, CHEMO ADMINISTRATION,
YOU’VE OVERLOOKED OR LEFT OUT ABOUT 40-50% APPROXIMATE OF THE COSTS OF CARING FOR CANCER.
LIKE WHAT DOES IT COST TO TREAT LUNG CANCER? A LOT OF VARIABLES THERE BUT IT’S A WHOLE
DIFFERENT QUESTION OR DIFFERENT LOOK THAN WHAT DOES IT COST TO TREAT CANCER FROM THE
SUBPOPULATION THAT HAS–STARTS WITH CHEMO. –AND I DRAW THAT 40-50% FROM SORT OF LOOKING
AT THE MARIOTA NCI STUDY THAT’S ALMOST TEN YEARS OLD NOW WHO LOOKEDDA THE COST OF INITIAL
CONTINUING AND END OF LIFE FOR EACH CANCER SITE, DISEASE SITE.
AND COMPARE THAT WITH THE OCM INITIAL NATIONAL AVERAGES FOR COST OF CARE FOR THOSE CANCERS
AND IT’S 40, 50% DIFFERENCE SO MY ASK AND DREAM WOULD BE PARTICULARLY BECAUSE OCS IS
A FIVE YEAR MODEL, I MEAN WE’RE WAY OUT TO CONSIDER THAT THERE’S AN OPPORTUNITY HERE,
TRULY FOR YOU TO LOOK AT AND I STAND HERE FOREWARNED THAT THERE’S ONLY GOING TO BE ONE
MODEL BUT THERE’S AN OPPORTUNITY FOR YOU TO HAVE SOME UMBRELLA OF DEALING WITH THE TOTAL
COST OF THE CARE FROM POINT OF DIAGNOSIS, BECAUSE THEREYA A LOT OF PROVIDER ORGANIZATIONS
OUT THERE AND THIS IS MAYBE IN THE THEME OF THE NCCN COMMENT THAT ARE INTERESTED, WILLING
TO STEP UP TO MANAGING TOTAL COST OF CARE FROM POINT OF DIAGNOSIS AT RISK EPISODES.
SO, THAT’S THE COMMENT I WANTED TO MAKE IS THAT THERE’S BIGGER WORLD THAN JUST CHEMO
INITIATION, ALTHOUGH, OCM’S DONE WELL AND IT WILL CONTINUE ON OCF, BUT THERE’S A BROADER
PICTURE AND I ENCOURAGE YOU NOT TO LEAVE OUT THE ECONOMICS OF THE FULL PICTURE OF CARING
FOR CANCER.>>REALLY APPRECIATE THAT AND I DID WANT TO
NOTE THAT IN DISCUSSIONING THIS, TPAOEUBDING SOMING SOMEWHAT WOULD WORK ON A FUTURE WORLD
ON A NATIONAL SCALE AND HOW DO WE PINPOINT A PARTICULAR STARTING POINT AND SO, CHEMO
INITIATION IS OFTEN TIMES MORE EASY TO IDENTIFY THAN WHEN THIS DIAGNOSIS HAPPEN?
I WILL SAY IN THE MODEL DESCRIBED IN THE RFI, THE MONTHLY POPULATION PAYMENT TO THE EXTENT
THE MEDICAL ONCOLOGIST IS CARING FOR SOMEONE WITH A CANCER DIAGNOSIS EVEN IF IT’S PRETREATMENT,
THAT WOULD MONTHLY PAYMENT WOULD START BUT THE TOTAL CAST OF CARE RESPONSIBILITY WOULDN’T
START UNTIL CHEMO SO TO THE EXTENT THAT YOU OR OTHERS MIGHT HAVE THOUGHTS ON HOW WE THINK
ABOUT THAT DIFFERENTLY, PLEASE CEMENT THOSE TO US.
>>WILL DO BUT I GUESS THE POINT IS THAT THERE’S ABOUT 40% OF THE COST OF CARE IFING FOR THE
PATIENT THAT OCCURRED BEFORE THE MEDICAL CONICOLOGYY THAT CHEMO BROUGHT IN AND THEREYA A TREMENDOUS
NEED FOR SOME MOTIVATION TO CLINICAL INTEGRATION AT POINT OF FIRST LINE RADIATION AND GET EVERYBODY
ON THE SAME PAGE AND THAT WOULD BE A NICE THING.
WE SPENT SOMETIME TALKING ABOUT HOW YOU GOET TO A APPROPRIATENESS AND UPSTREAM CARE I GUESS
FOR THE BUNDLE AND HOW HOW DOES IT INITTIAIT AND NOW DO YOU INITTIAIT STARTING CHEMO THERAPY.
WHAT LAURA SAID IS TRUES, FROM THE POINT PERSPECTIVE EVERYBODY UNDERSTANDS WHEN CHEMO STARTS NOBODY
HAS TO QUESTION OR WORRY ABOUT. IS THERE ROOM FOR FIGURING OUT HOW EARLY ON
I AS A MEDICAL ONCOLOGIST AM TAKING RESPONSIBILITY FOR FIGURING OUT WHAT’S HAPPENING BEFORE I
GET TO THE CHEMO THERAPY, YES? IT’S A GREAT COMMENT TO PUT IN, WE HAVE SPENT
A LOT OF TIME TRYING TO FIGURE OUT NOT NECESSARILY ONCOLOGY BUT MORE BROADLY IN THE INNOVATION
CENTER, HOW DO I SET UP THE INCENTIVES–IT’S A DIFFERENT STRUCTURE TO SOME DEGREE, RIGHT
TO HOLD YOU ACCOUNTABLE TO THE CARE HAPPENING BEFORE SO AM I LOOKING AT THE COST OF PRECARE,
LIKE WHAT IT LOOK LIKE IN THE ONCOLOGY SPACE, WE CAN IMAGINE AN ELECTIVE SURGERY SPACE WHERE
IT MIGHT LOOK LIKE CONSERVATIVE THERAPY AND BUT IN ONCOLOGY, OFTEN TIMES THE CHEMO THERAPY
IS ONE OF THE PRIMARY TREATMENTS THAT’S GOING TO HAPPEN ONE WAY OR THE OTHER, SO I GUESS
WHAT I WOULD WANT TO HEAR FROM YOU AND OTHER WHO SPENT TIME THINK BEING IT IS WHAT DOES
THAT PRESPACE LOOK LIKE, DOES THERE WAY I TO KNOW IT’S HAPPENING IN THE CLAIM SO WE
COULD THINK ABOUT IT, WHAT’S THE INCENTIVE TO SORT OF EMPHASIZE BETTER UPFRONT PLANNING
AND HOW MIGHTY LOOK AT IT, I MEAN HONESTLY IF YOU’RE PRACTICE WAS PRACTICE, KICK PRACTICE
FOR THE DAY, WHAT WOULD IT BE THAT WILL HELP US BETTER UNDERSTAND HOW TO THINK ABOUT THE
INSECTIVES IF WE WERE ABLE TO MOVE UP FROM THE CHEMO THERAPY ADMIN TO SOMETHING THAT
HAPPENS A BIT SOONER. STPH-RBS APPRECIATE IT.
>>I WILL RESPOND TO THOSE.>>YES.
>>FUNDAMENTALLY IT’S JUST A PRICE, AN EPISODE,.>>WELL POINT OF DIAGNOSIS, IT’S AN EPISODIC
PAYMENT TO TREAT THAT CANCER FROM–YEAH AND WE HAVE TO KNOW HOW WE KNOW THAT CLAIM COMING
WITH THE POINT OF DIAGNOSIS AND BBCRA, WEINISHIATE THE POINT OF ADMISSION WHICH AGAIN LIKE THE
CHEMO THERAPY IS AN EASY CLAIM DROP IT IS CRITICAL, I WANT TO SAY NANOTHING IN CONVERSATION
BY THE WAY PRECLUDES IN THE INNOVATION CENTER WE WILL LOOK AT EVALUATION RESULTS OF CURRENT
ONCOLOGY CARE MODAND HE WILL I DON’T WANT TO SAY IN ANY WAY THAT WE’RE PURSUING THIS
BECAUSE WE WANTED TO MAKE SURE WE WERE MOVING FORWARD IN THE ONCOLOGY CARE SPACE THERE,
‘S NO QUESTION GENERALLY AS OUR EVALUATION RESULTS COME IN ARE IF THE ONCOLOGY CARE MODEL
IT WILL BE LOOKEDDA THE CLOSELY, WE WILL HAVE THE CONVERSATIONS ABOUT WHAT CAN AND CANNOT
HELP ONCE WE DEMONSTRATE IMPROVED QUALITY REDUCED COSTS ASSUMING OUR PRELIMINARY RESULTS
WE HAVE OF CONTINUE TO GROW. I WANT TO MAKE SURE THAT I JUST DISTINGUISH
THOSE TWO. WE WILL CONTINUE THAT PATH OF LOOKING AT THE
RESULTS OF THIS MODEL LIKE ALL MODELS TO SEE WHAT THEIR IMPLICATIONS CAN BE ON THE NATIONAL
SPACE OR NOT. IT’S VERY PRELIMINARY FOR THAT.
I JUST WANT TO MAKE SURE WE’RE CLEAR. YES?
>>THANK YOU.>>WE HAVE INCLUDE A SMALL BREAK IN OUR LINE
UP, DO FOLKS FEEL LIKE THEY WANT A BREAK, I SEE NO, NO, RATHER JUST PRESS ON THROUGH
AND GET OUT OF HERE. OKAY, TOTALLY FINE.
>>I’M SARAH SOCIAL WORKER AT WASHINGTON WASH MEDSTAR MY QUESTION CAN BE APPLIED TO ALL
FOUR CAT 84YS. I’M INTERESTED IN OW IT’S GOING TO INCORPORATE
THE SUPPORTIVE CARE SPECIFICALLY MENTAL HEALTH. I KNOW SOMEBODY HAD TOUCH OFFICE OF DIVERSITY
THIS THE PSYCHOTHERAPY, I JUST, YOU KNOW BEING–HAVING FIRST HAND EXPERIENCE WITH PATIENTS, I FIND
THAT THEIR MENTAL HEALTH SOMETIMES DIRECTLY INTERFERES WITH THEIR TREATMENT.
ESPECIALLY WITH PATIENT WHO IS HAVE SEVERE ANXIETY, DEPRESSION ADJUSTMENT DISORDER, SOMETIMES
THEY HAVE TO STOP THEIR TREATMENT ALTOGETHER AND GO TO THE E. D. FOR SUICIDAL IDEATION
OR EXTREME ANXIETY SO I’M JUST INTERESTED IN HOW THAT WILL BE REFLECTED?
TSO IN OCM WE HAVE A COUPLE DIFFERENT WAYS THAT WE TRY TO PROMOTE GOOD CARE OF THE WHOLE
PATIENT INCLUDING PSYCHOSOCIAL HEALTH NEEDS ONE THAT WE HAVE A QUALITY MEASURE IS AROUND
DEPRESSION, SCREENING AND TREATMENT AND THEN WE ALSO HAVE AN ELEMENT IN OUR REQUIRED CARE
PLAN FOR ALL PATIENTS THAT LOOKS AT PSYCHOSOCIAL HEALTH NEED CANS DEFINING AND TREATING THOSE
AS ARK DENTIFIED AND WE ALSO BELIEVE THE TOTAL COST OF THE CARE RESPONSIBILITY, LIKE YOU’RE
DESCRIBING WILL HELP FOLKS INTERVENE EARLY TO AVOID THAT EMERGENCY DEPARTMENT VISIT ET
CETERA, CERTAINLY IF THERE ARE OTHER WAYS IN THIS FUTURE MODEL THAT WE COULD BETTER
SUPPORT SUPPORTIVE CARE WE WOULD LOVE TO HEAR ABOUT THOSE NSO I JUST USE AN EXAMPLE, THERE’S
A PATIENT OF MINE WITH EXTREME ANXIETY AND I DID REFER HIM TO AN OUTPATIENT PSYCHOTHERAPIST,
BUT THE WAITING LIST IS JUST INSANE. HE’S ACTUALLY HAD TO GO TO THE E. D. MULTIPLE
TIMES BECAUSE WE HAD EXTREME ANXIETY REGARDING NEEDLES SO HE’S ACTUALLY PASSED OUT WHEN YOU
KNOW THE CHEMO THERAPY WAS INITIATED AND HE–THEY HAD TO CALL RAPID RESPONSE, SO, HE WENT TO
THE E. D. AND HE COULDN’T GET HIS TREATMENT FOR MULTIPLE DAYS.
SO I GUESS I’M MORE INTERESTED IN, WILL THERE BE AN INCENTIVE TO HAVE LIKE A PSYCHOTHERAPIST
OR PSYCHIATRIST ONSITE TO SUPPORT THE ONCOLOGY STAFF?
>>I THINK WE CAN GO AHEAD AND TAKE THE FEEDBACK THAT THAT’S SOMETHING YOU WOULD LIKE TO SEE
INCLUDE INDEED THE MODEL.>>THANK YOU.
>>THANK YOU.>>HELLO I’M CAROLINE AND I’M A DIETITIAN
NUTRITIONIST AT THE EN–STRATEGIESITUTE ASK SO I’M WITH SARA AND PIGGYBACKING OFF THAT,
SO CURIOUS ABOUT NUTRITION SERVICES AND IF THAT WILL BE ENCLUEDED.
ALSO A COUPLE EXAMPLES WORKING WITH THE PATIENTS IS I HAVE- MOST OF OUR PATIENTS ARE MEDICARE,
MEDICAID AND THE ONCOLOGY NUTRITION SERVICES ARE NOT COVERED AND SO A LOT OF TIMES THEY
DO HAVE TO STOP TREATMENT FOR MALNUTRITION AND LOSING WEIGHT, UNTIL THEY CAN GET THAT
UNDER CONTROL. I ALSO HAVE LOTS OF PATIENTS WHO HAVE FEEDING
TUBES AND THE FORMULAS DON’T GET COVERED O WE ABSORB THE COST OR TRY TO FIND A PRIVATE
DONOR WHICH CAN TAKE A LONG TIME AND BY THE TIME WE FIND THE RESOURCES, THEY ARE VERY
MALNOURISHED WHICH IS THE TREATMENT AND ULTIMATE OUTCOMES SO BASICALLY YOU’RE CURIOUS HOW THE
NUTRITION WILL BE INCORPORATED IN THIS.>>I THINK WE MAKE THE SAME COMMENT, WE’LL
GO AHEAD AND TAKE THAT AS FEEDBACK FROM YOU THAT–AND RIGHT NOW, OBVIOUSLY THE IDEA IS
FOR THE PRACTICES TO HAVE THE ABILITY TO CONTINUE TO COORDINATE THOSE SERVICES AND POTENTIA
WILY WITHIN THEIR SCOPE, THEY CAN CHOOSE TO OFFER, NOT OFFER, RIGHT NOW.
I THINK TO THE EXTENT THAT YOU’RE REQUESTING THAT THAT BE IDENTIFIED AS A MORE FORM AT
COMPONENT OF THE MODEL WE CAN TAKE THAT BACK.>>YEAH, I’LL NOTE SOME PRACTICES IN OCM RIGHT
NOW, DO HAVE NUTRITIONISTS ONSET, ET CETERA BUT AS CHRIS SAID WE’LL NOTE THAT AS SOMETHING
FORM AT, THANKS.>>AND ONE OTHER THING WITH THAT IS I AM ONSITE,
I THINK THE ISSUE IS WE DON’T HAVE ENOUGH BECAUSE WE CAN BE THE GET MORE ADEQUATE STAFFING
BECAUSE OF THE REIMBURSEMENT AND LACK OF IS WHAT THE ADMINISTRATION TOLD US.
>>[INDISCERNIBLE] NEW CENTURY HEALTH, I JUST WANT TO RAISE A COUPLEY COMMENTS ABOUT THE
PAYMENT MODEL AND THE RISK APPROACH HERE AND JUST SAY FIRST OF ALL, CENTURY SUPPORT HAS
A STRONG RISK TO CAPITATION WE’VE SEEN IT WORK WELL, WE KNOW MANY PRACTICE CAN DO IT
SOMETIMES WITH A PARTNER AND AT THE SAME TIME, ALSO RECOGNIZE THAT PRACTICES AREN’T ALL THERE
AND TAKE A SIGNIFICANT AMOUNT OF TIME AND RESOURCES TO GET THERE, SO I GUESS I WOULD
JUST RECOMMEND THAT CMS LOOK CAREFULLY AT THE NUMBER AND THE KHARBGTISTICS OF PRACTICES
THAT EITHER CHOOSE TO STAY IN ONE SIDE OF RISK IF THEY HAD V THAT CHOICE OR DROP FROM
THE MODEL IF THEY’RE FACE WIDE MAKING THAT DECISION.
AND JUST REALLY HAVE THAT INFORMED HOW STRONG TO GO ON THE UPSIDE ONLY VERSUS TWO SIDED
RISK CONTINUUM BUT WE SHARE THE GOAL OF HAVING BOTH AS MANY PRACTICES IN THIS MODEL AND IN
THE TWO SIDED RISK AND SUCCEEDING IN THE TWO SIDED RISK BUT IT’S ALL IMPORTANT BUT THE
BALANCE IS IMPORTANT AS WELL, AND THEN SECONDLY AS PART OF THAT, WE ALL KNOW THAT THE DEVIL’S
IN THE DETAILS OF THE PRICING MODEL SO, YOU KNOW SO WE HAVE TALKED A LOT WITH YOU ALL
ABOUT THE MAJOR DRIVERS OF COST HERE BEING NOT JUST CANCER TYPE BUT CANCER SUBTYPE AND
PROGRESSION SO THAT TO THE EXTENT THAT THE PRICING MODEL CAN INCORPORATE SUBTYPE AND
PROGRESSION WE THINK THAT WOULD BE AN IMPROVEMENT, ONE OF THE CANCER TYPES SPECIFICALLY THAT
WAS NOT MENTIONED IN THE RFI, IS MULTIPLE MYELOMA, THAT HAS CAUSED CONSIDERABLE DISTRESS
AMONG PROVIDERS ESPECIALLY IF YOU HAVE A PARTICULARLY HIGH CASE MIX OF THAT.
SO THAT MIGHT BE ONE TO HAVE SPECIAL CONSIDERATIONS FOR ASK THEN I THINK WE WILL OBVIOUSLY TAKE
MORE TIME TO DIGEST WHAT WAOUF PUT OUT. BUT I WOULD SAY, GIVEN THE COMPLEXITY OF THE
PRICING METHODOLOGIES, WE WOULD ASK FOR ANOTHER OPPORTUNITY TO REVIEW A VERY DETAILED PRICING
METHODOLOGY IN WRITING BEFORE IT IS FINALIZED. SO JUST ASKING FOR KIND OF ONE MORE POINT
ALONG THIS CONTINUUM OF STAKEHOLDER FEEDBACK, WE WOULD FEEL THAT WOULD BE EXTREMELY HELP
EXCLUSIVELY AVOID THE CHALLENGES WE HAD WITH THE PRICING METHODOLOGYY SO I THINK THAT’S
ALL, THANK YOU.>>ALL RIGHT.
ALL RIGHT, HOLD ON ONE SECOND, THREE FOR THE PHONE, OKAY?
>>ON THE PHONE?>>THANK YOU THE NEXT QUESTION ON THE PHONE
COMES FROM FRANKLIN WITH GENESIS [INDISCERNIBLE] YOU MAY GO AHEAD.
THANK YOU, I’M A UROLOGYST AT SAN DIEGO PARTNERS, AND PUT IN MY QUESTION
FOR EARLIER–PROSTATE CANCER AND DID COMMENTS FROM THE PREVIOUS COMMENTS REGARDING EPRO,
REPORTING OF QUALITY DATA AND ASSISTING CLINICAL STAGING EVEN THOUGH IT’S NOT PERINENT TO THE
CURRENT DISCUSSION, I JUST WANTED TO MENTION THAT WE SEE OPPORTUNITIES TO LEVERAGE TECHNOLOGY,
WE’VE BEEN PUSHING EPRO FROM PATIENT SMART PHONES DIRECTLY TO THE EIN, R SO IT IS TECHNICALLY
FEASIBLE AND IN UROLOGY EVEN THOUGH WE’RE A SMALL SPECIALTY, 2 PERCENT OF ALL MEDICINE
THERE’S TWO LARGE CLAUDE BASED PLATFORMS THAT ARE PULLING DATA DOCTOR ECTOMYOSINLY FROM
THE EMR AND THIS PROVIDES PHYSICIAN FEEDBACK AND A LOT OF THE QUALITY REPORTING MEASURES.
SO I WOULD JUST ENCOURAGE TO INCENTIVIZE THE USE OF TEGGIC–STRATEGICNOLOGY AND ALSO TO
PERHAPS GET A COMMITTEE TO EVALUATE EXISTING TECHNOLOGY SO THAT WE CAN LEARN FROM EACH
OTHER. SO I’LL STOP THERE, SORRY THAT IT’S A DELAYED
COMMENT BUT THIS WAS THE OPPORTUNITY I WAS TKPWOEUFPB SPEAK.
>>OH NO PROBLEM AT ALL. THANK YOU VERY MUCH FOR YOUR COMMENTS.
AND WE HAVE TWO MORE ON THE PHONE.>>OKAY, THE NEXT QUESTION ON THE PHONE COMES
FROM VALERIE [INDISCERNIBLE] WITH JEFFERSON HEALTH.
YOU MA I GO AHEAD.>>THANK YOU VERY MUCH FOR THE OPPORTUNITY
AND FOR THIS GREAT SESSION TODAY, MY QUESTION WAS GOING BACK TO INITIAL COMMENT MADE IN
TERMS OF ALIGNMENT OF ONCOLOGY MODELS AND SPECIFICALLY, RELATED TO THERE’S BEEN A PROPOSED
RADIATION ONCOLOGY MODEL AND NOW WE’RE SEE THANKSGIVING ONCOLOGY CARE FIRST MODEL, IS
IT THE INTENTION OF CMMI TO,A HRAO*EUPB THOSE IN TERPS OF CREATING A SINGULAR MODEL, MOVING
FORWARD?>>NO.
RIGHT NOW WE’RE LOOKING AT MAINTAINING THOSE SEPARATELY, OBVIOUSLY THE RADIATION ONCOLOGY
MODEL IS STILL AS PROPOSED. THE COMMENT PERIOD THAT’S A MANDATORY MODEL,
THE COMMENT PERIOD HAS CONCLUDED AND WHY ARE IN THE PROCESS OF READING ALL OF THOSE COMMENTS,
BUT IT IS A PERSPECTIVE PAYMENT THAT IS VERY UNIQUE TO THE KIND OF NEARBY AREA THAT RADIATION
ONCOLOGY IS AND WE SEE THE ROLES OF THE RADIATION ONCOLOGIST AND THE MEDICAL ONCOLOGIST IS DIFFERENT
THAT THE MEDICAL ONCOLOGIST IS DOG COORDINATING FOR THE ENTIRE TREATMENT WHERE THE RADIATION
ONCOLOGIST IS THE IMPORTANT PERIOD OF TIME THAT TURN IRBING THE DESIGN BEHIND THE ENERGY
AND RADIATION ONCOLOGY. SO APPROXIMATE WE HAVE TO INCLUDE IT IN THE
ASSESSMENT UNDER THE PROPOSED RADIATION AND ONCOLOGY CARE MODEL, IT’S FEASIBLE BECAUSE
IT’S A DIFFERENT TYPE OF MODEL, AND WE DON’T SEE OURSELVES PUTTING THOSE TWO TOGETHER IN
SORT OF A SINGLE ONCOLOGY MODEL AT THE MOMENT D.
>>NEXT IS [INDISCERNIBLE] WITH THE UNIVERSITY OF ALABAMA AT BIRMINGHAM.
YOU MAY GO AHEAD.>>CAN YOU HEAR ME, PERFECT, SO I AND TRANSFORMATIONS
AND TO ECHO WHAT AND FOR THOSE THAT ARE TOO NOT HOT ABOUT IN FLEXIBLE
BECAUSE I THINK THE LITERATURE INCREASINGLY IS POINTING TO THAT BENEFITS PATIENTSS AS
WELL AS POTENTIALLY THE HEALTH SYSTEM, IT IS NOT A SMALL AND FOR THE PATIENTS IN TERMS
OF WHEN THOSE REQUIREMENTS’RE GOING TO BE CAUSING KIND OF FOR THOSE PRACTICES THAT PERHAPS
HAVE NOT STARTED WORKING ON THIS ALREADY.>>YEAH.
THANK YOU.>>THANK YOU THE NEXT QUESTION IS FROM CHERYL
PRINCE WITH WEST CLINIC TENNESSEE YOU MAY GO AHEAD.
>>YES, THANK YOU VERY MUCH. ONE OF MY QUESTIONS OR MAYBE CONCERN SAYS
OR SUGGESTIONS INVOLVE THE TWO SIDED RISK GRANTED THE 12TH PAGE I READ, I DID PICK UP
THEY WERE ELECTRICKING AT A THREE TO 4 PERCENT COST SAVINGS DISCOUNT, I WOULD LIKE TO ENCOURAGE
THAT YOU RETHINK THOSE PERCENTAGES, THE FOUR% IS CLOSER TO THE ORIGINAL TWO SIDED RISK FOR
OCM, AND I THINK MANY OF US COMFORTED A BIT WHEN THE ALTERNATIVE TWO SIDED RISK WHICH
CAME COULD YOU TELL WHICH HAS THE TWO AND HALF PERCENT IN ADDITION THE IDEA OF HAVING
THE SAVE ZONE WHEN YOU LOOK AT YOUR TARGET VERSUS YOUR ACTUAL–VERSUS BENCHMARK, I WOULD
REALLY ENCOURAGE THAT YOU CONSIDER THAT AND THEN JUST THE SECOND POINTED TO TAG ON MULTIPLE
MYELOMA WOULD BE A REALLY GREAT ONE TO LOOK AT CLOSELY BECAUSE I’VE HEARD ACROSS PRACTICES
THAT THERE ARE A LOT OF QUESTIONS PERTAINING TO THAT.
THANK YOU.>>I THINK WE CAN CERTAINLY SAY THAT OUR CURRENT
ALTERNATIVE TWO SIDED RISK ARRANGEMENT HAS BEEN ONE OF THE DRIVERS BEHIND THE THINKING
WE’VE BEEN HAVING IN TERMS OF THE MODERATE, MODEST RISK AS WE LOOK AT LOOKING AT RISKS
HERE, I THINK THE QUESTION IS REALLY WHAT WOULD A–WE KNOW WHAT THAT LOOKS LIKE, I THINK,
WE’VE BEEN CHALLENGED TO THINK EVEN MORE BROADLY ABOUT SOME KNOW WHO MIGHT WANT TO TAKE MORE
RISK MIGHT LOOK LIKE. AND I DON’T KNOW THAT WE KNOW WHAT THE RATE
POINT THERE IS, IN ADDITION TO GETTING SOME GOOD FEEDBACK ON WHAT THE ALTERNATIVE RISK
MODEL LOOKS LIKE SO I WILL JUST THROW THAT OUT THERE.
>>THANK YOU FOR THE OPPORTUNITY. SECOND ACTS ARE ALWAYS TOUGHER AND I HAPPENING
THAT WE ALL PUT A LOT OF EFFORT INTO OCM, AND WE ALL UNDERSTOOD WE MAY NOT GET IT RIGHT
ON EITHER SIDE OR ON ALL SIDES OF THIS SO IT REALLY BECOMES IMPORTANT THAT IT GETS RIGHTER
FOR THE NEXT VERSION AND HAVING SAID THAT, ESPECIALLY IF YOU’RE EXPECT BEING PEOPLE TO
TAKE ON THE RISK, THE CLINICIANS PERSPECTIVE IS WITHOUT INCLUDING CLINICAL STAGING AND/OR
CURRENT CLINICAL STATUS IN THE METHODOLOGY, IT MAKE ITS VERY DIFFICULT FOR THEM TO UNDERSTAND
HOW THIS WORKS AND WHY IT WOULD MAKE SENSE AND GIVEN THAT IT’S A VOLUNTARY MODEL, THE
CONCERN THAT WE HAVE HEARD IS THAT WITHOUT WITHOUT THAT BEING AT LEAST SOMEWHAT ADDRESSED
OR EVEN TOUCH OFFICE OF DIVERSITY IT, IT MAKE ITS HARD FOR THEM TO WANT TO PARTICIPATE.
I APPRECIATE THE COMMENTS THAT YOU MADE ABOUT THE FACT THAT YOU WANT TO DECREASE THE BURDEN
AND THE PLAN IS NOT DEFINITELY TO INCREASE IT AS FAR AS REPORT SUGGEST CONCERNED, I’M
GLAD JESS BROUGHT THAT UP BUT AGAIN IF THERE ARE OTHER WAYS TO INCORPORATE THIS, WE SUGGEST
AS YOU KNOW USING DRUGS AS A PROXY FOR CLINICAL STATUS, THERE MAY BE OTHER WAYS TO ACHIEVE
THAT BUT GIVEN THE COMPLEXITY OF CANCER AND CANCER CARE WITHOUT HAVING THAT KIND OF A
CLINICAL LINK, I THINK YOU WILL HAVE A DIFFICULTY. JUST THE WAY THAT IT IS.
AND WE’VE HEARD A LOT TODAY ON THE QUALITY SIDE, REGARDING ADHERENCE TO GUIDELINES, I
WILL ALSO ADD BECAUSE AGAIN TO DECREASE THE BURDEN, THERE ARE A LOT OF FOLKS THAT ARE
INVOLVED IN ROLLING PATIENTS IN LARGE REGISTRIES THAT ARE VALIDATED AND AUDITED, ET CETERA,
USING THOSE DATA AND THOSE OUTCOMES DATA IF NOT DIRECTLY OR AT LEAST TO INFORM THE QUALITY
MEASURES YOU WANT TO USE, AGAIN NOT TO HOLD UP BPCI ADVANCES, THE ULTIMATE THAT I HAVE
BEEN ABLE TO DO THAT AND I THINK THAT GOT A LOT OF BUY IN FROM THE CLINICIANS PERSPECTIVE.
>>YOU HAVE REGISTRIES TO RECOMMEND TO US WITHOUT CO MEASURES FROM THEM.
>>I THINK WE HAVE A HOST OF PEOPLE HERE REPRESENTING THOSE REGISTRIES THAT WOULD BE BETTER QUALIFIED
BUT SURE.>>I’M ONLY NOTING, I CERTAINLY DON’T PERSONALLY
KNOW THE PAN OPERATING GLOBALLILY OF REGISTRIES, IT’S AN AREA OR A PLACE WHERE THE MEDICAL
COMMUNITY ITS HAS BEEN IN PLAYER AND SO IT’S CERTAINLY OF INTEREST TO US TO SUPPORT THAT.
I DON’T KNOW HOW IT WOULD PLAY IN HERE BUT IT WOULD BE GOOD IN COMMENTS IF PEOPLE HAVE
THEM TO LET US KNOW IF THERE ARE A PARTICULAR ELEMENTS IN THERE THAT THEY THINK ARE VERY
USEFUL THAT WOULD BE APPLICABLE TO ALL OF THE PARTICIPANTS, POTENTIAL PARTICIPANTS IN
THE MODEL. YEAH.
>>GREAT.>>SURE.
>>THANK YOU.>>SANDY MARKS, ON STAFF WITH THE AMERICAN
MEDICAL ASSOCIATION, WE VERY MUCH APPRECIATE THAT YOU’RE PROPOSING A VOLUNTARY MODEL, KEEP
IT THAT WAY, PLEASE.>>ALSO APPRECIATE HAVING THE OPPORTUNITY
TO PROVIDE INPUT AND THE PREVIOUS PERSON SAID THERE WILL BE MORE OPPORTUNITIES TO PROVIDE
INPUT ON A MORE DETAILED OUTLINE OF THE MODEL, THERE’S A FEW WAYS FEATURES OF THE OF THE
MASON MODEL, FOR PROPOSAL NATION WOULD NOT HOLD PARPII SYSTEMS EIGHT PARTICIPATE IN A
TRIALING MAKING IT ACOULD YOU WANTABLE FOR THE COST OF MANAGING BEFORE THEY HAD CANCER
AND SO EARLY EARLY MENTION THE CARDIOVASCULAR ISSUES, PATIENT HAS A FALL BECAUSE THEIR HYPER
TENSION MEDS ARE CHANGED FOR EXAMPLE AND HAS TO GO TO THE EMERGENCY DEPARTMENT, THAT SHOULDN’T
BE THE FAULT OF THE ONCOLOGIST PRACTICE TO REMEDY IN THEIR TOTAL COST OF CARE MEASURE,
AND AND THE INFLUENCE, SO THAT’S GOING TO BE A PARTICULAR PROBLEM IS THE PARTICULAR
PROBLEM IS THE OTHER PHYSICIANS WHO ARE TAKING CARE OF THE PATIENT OR TAKING CARE OF THE
PATIENT’S OTHER CONDITIONS ARE IN THE SAME PRACTICE AS THE PARTICIPATING ONCOLOGIST IS,
AND THEY DON’T HAVE ANY PAYMENT MODEL, EITHER, SO THEY’RE NOT GETTING EXTRA HELP TO BE ABLE
TO PROVIDE THAT EXTRA SUPPORT TO OTHER PATIENTS TO MANAGE THEIR CONDITIONS SO WE WOULD LIMIT
THE RISK TO THE COST OF THE ONCOLOGY CARE, WE ALSO WOULD EXCLUDE THE PRICES.
AND THEY ARE HELD ACCOUNTABLE, WHAT’S ACCOUNTABLE FOR PARTICULAR DRUGS, A MODEL AS MASON DOES,
AND AS ASCO AND NCTN HAVE SPOKEN ABOUT PREVIOUSLY, IT LOOKS AT QUALITY OF CARE, MEASURED ACCORDING
TO OUR PHYSICIANS FOLLOWING THOSE CLINICAL PATHWAYS, VERY DETAILED CLINICAL PATHWAYS
IS GOING TO LOOK AT WHETHER DRUGS ARE BEING APPROPRIATELY USED AND THAT SHOULD BE THE
MEASURE, ARE WE USING THE RIGHT DRUGS, AT THE RIGHT TIME FOR THE RIGHT CIRCUMSTANCES,
NONAPOPTOTIC THE HOW MUCH DOES THIS DRUG COST VERSUS ANOTHER DRUG.
AND FINALLY, MASON USES A GREAT DEAL OF INFORMATION ON EACH PATIENT, SO THAT RISK ADJUSTMENT CAN
BE BASED ON ALL THE FACTORS THAT GO INTO THE COST AND THE QUALITY OF THE PATIENT THAT CONFRONTED
THE PHYSICIAN AT THAT TIME. SO IT’S NOT HISTORICAL, IT’S NOT WHAT WERE
THE PRACTICES PATIENT POPULATION. LAST YEAR AND TRYING TO PREDICT WHAT THEY’RE
GOING TO NEED NEXT YEAR. IT TAKE SPWOS ACCOUNT A LOT OF DIFFERENT FACTOR
ASKS THIS IS WHY THE PTACH RECOMMENDED IT TO CMS BECAUSE IT TAKE SPWOS ACCOUNT VERY
SPECIFIC FACTORS THAT GO INTO EACH PATIENT’S CARE.
SO, THANK YOU.>>THANK YOU.
>>[INDISCERNIBLE], I WAS BRIEF BEFORE SO I COULD HAVE ANOTHER CHANCE TO COME UP HERE
BUT NOW WE GET TO TALK ABOUT RISK. SO YOU KNOW WE’VE TAKEN AN OPPORTUNITY OVER
THE PAST YEAR TO REALLY TALK TO PRACTICES THAT ARE IN OCM, TRY TO UNDERSTAND WHAT IS
THEIR DECISION MAKING AROUND TWO SIDED RISK, IT REALLY REQUIRES A FEW THINGS WE SEE AS
COMMON THEMES, ONE IS SUFFICIENT SIZE, PREDICTION MODEL AND EVEN IF WE MAKE IMPROVEMENTS TO
IT, IT WILL NOT BE EXACT AND OUTLIERS DO THROW SMALL PRACTICES FAR MORE THAN THEY’RE GOING
TO THROW LARGE PRACTICE THAT HAVE A MORE SUFFICIENT COURSE.
SECOND IT REQUIRES ADMINISTRATIVE RESOURCES, THE REALLY UNDERSTAND THE DATA, UNDERSTAND
THEIR PATIENT POPULATION THROUGH THAT CLAIMS DATA COMING IN, TO BE ABLE TO PREDICT WHAT
WILL HAPPEN FOR THEM IN THE FUTURE AND THEN THIRD, IT REQUIRED THE FINANCIAL MECHANISM
WHETHER THAT BE REINSURANCE OR SUFFICIENT CASH RESERVES TO REALLY SAY I’M GOING TO TREAT
PATIENTS TODAY, ASSUMING ONE REVENUE STREAM AND THEN 18 MONTHS FOR NOW WE WILL RECONCILE
THAT AND MAY BE WRITING OR RECEIVING A CHECK. I WILL POINT OUT THAT IN YOUR METHODOLOGY,
HAVE YOU OTHER OPTIONS. THROUGH THE MPP, YOU HAVE AN OPPORTUNITY TO
LOOK AT COST THROUGH THE PERFORMANCE METHODOLOGY RATHER THAN THE PAYMENT METHODOLOGY.
AND IN YOUR PAYMENT METHODOLOGY TO MAKE A PORTION OF MPP VARIABLE BASED UPON QUALITY
AND COST SCORES, AND IN DOING SO IMAGINE YOU’RE IN THAT PRACTICE OF SEEING IF I KNOW VERY
SIMILAR TO MEPS, IF I KNOW THAT NEXT YEAR I’M EITHER GOING TO GET AN INCREASE OR A DECREASE
TO MY RATES I CAN PLAN FOR THAT AHEAD OF TIME AND KNOW HERE’S WHAT I CAN PAY MY STAFF, HERE’S
WHAT I CAN PAY MY PHYSICIANS AND SO ON. VERSUS I’M GOING TO PAY THEM THIS AMOUNT TODAY,
AND I MAY HAVE TO PAY A PORTION BACK TO SOMEONE ELSE BUT I’M DEFINITELY NOT RECOOPING PART
OF THEIR PAYCHECKS RIGHT FOR MY NURSES TO BE ABLE TO COVER THAT.
SO YOU DO HAVE OPTIONS THROUGH MPP TO DO SOMETHING DIFFERENT.
SO WHAT THAT ALL WILL DO IS YOU HAVE HEARD, YOU KNOW FROM MASON AND OTHERS ABOUT OTHER
OPTIONS IN THE COST METHODOLOGY THAT SHOULD BE EXPLORED.
BUT PERHAPS IF YOU DO THAT THROUGH THE PERFORMANCE METHODOLOGY, YOU HAVE A LOT MORE FREEDOM TO
EXPLORE, WHAT TYPE OF RISK ADJUSTMENTMENT I CAN DO, HOW CAN I KIND OF EVOLVE THAT EACH
PERIOD TO IMPROVE UPON IT AND IMPROVE UPON IT AND I THINK THAT’S FAR LESS RISK TO DO
THAT FOR A PERFORM APSE METHODOLOGY AND CONSIDER SOMETHING ELSE ON THE PAYMENT RISK METHODOLOGY
UPON UPON ASHES BROAD. THANK YOU.
>>I WAS GOING TO SAY, SO SOMETHING MORE LIKE THE PRIMARY CARE FIRST MODTHEY’LL WE ANNOUNCED
A FEW SEASON–COUPLE MONTHS AGO.>>SO I’M NOT FULLY BRIEFED ON THAT PARTICULAR
MODEL, YOU KNOW WE PUT SOME MATERIALS ON P-COST THAT HAVE SIMILAR IDEAS OF HEY, LET’S MAKE
PART OF THAT NPP VARIABLE, AND IT REALLY DOES ALLOW FOR THE PRACTICES TO KNOW WHAT THEY’RE
GOING TO RECEIVE IN REVENUE AND CAN PAY OUT.>>WOULD YOU SO WE HAVE THE TWO COMPONENTS
WE’RE TALKING ABOUT PUTTING MORE OF THE PERFORMANCE ELEMENT RISK ADJUSTMENT, QUALITY, ADJUSTMENT
ON TO THE MPP WHICH IS GOING TO BE THE SORT OF A WE WOULD HOPE LIKE A STANDARD SORT OF
PRACTICE PAYMENT REPLACEMENT, WHAT’S HAPPENING, IF I MISS TODAY, I APOLOGIZEOT TOTAL COST
OF CARE ASSESSMENT, WOULD YOU DO,A WAY WITH THAT ENTIRELY SO, WHAT IS YOUR–
>>SURE. SO YEAH, WE HAVE SHARED AND WE SHARED IT WITH
SOME OF THE MEMBERS OF CMMI TEAM AND AM WILLING TO SHARE IT MORE BROADLY IS A LOOK AT A PERFORMANCE
METHODOLOGY THAT’S THREE PRONGED. RIGHT?
TAKING A LOOK AT QUALITY, CLINICAL TREATMENT PATHWAY ADHERENCE AND TAKING A LACK AT COST
MEASUREMENT, WHETHER IT BE TOTAL COST OF CARE OR TARGETED COST OF THE CARE AND THAT’S YOUR
OPPORTUNITY TO IMPROVE AND EXPLORE METHODOLOGIES AND ON THE PAYMENT METHODOLOGY, RATHER THAN
RECONCILIATION, YOU WRITE ME A CHECK, I WRITE YOU A CHECK KIND OF IDEA, IS TO MAKE A PORTION
OF THAT MPP VARIABLE BASED UPON PERFORMANCE IN THE LAST PERIODS PERFORMANCE METHODOLOGY.
AND YOU KNOW, SO, I MAY BE AT 104% OF WHERE I WAS LAST YEAR BECAUSE I DID WELL, OR I MAY
BE LESS THAN WHAT I WAS LAST YEAR BECAUSE I DID POORLY.
SO IT’S REALLY IN THE PPP. SO NOW THAT YOU SAY THAT IT’S LIKE DO I REMEMBER
BUT IT ESCAPED ME. THANK YOU VERY MUCH.
>>THANK YOU.>>BARBARA AGAIN, I WASN’T BRIEF THE FIRST
TIME AND IS PROBABLY WON’T BE BRO THIS TIME BUT IT’S OKAY.
>>FIRST I WANT TO THANK THE SHOUT OUTS FROM OTHER PEOPLE FOR THE MASON PROJECT.
AND I WILL ADMIT THAT THESE PAST TWO AND HALF YEARS IN THE AMA PRESIDENCY AS I’VE GONE AROUND
THE COUNTRY A LOT OF MY ASSIGNMENTS HAVE BEEN OF INTEREST TO ONCOLOGY GROUPS AND I’VE TAKEN
THE TIME WHEN I GO AHEAD THE COUNTRY TO TALK ABOUT THE ONCOLOGY CARE MODEL, TALK ABOUT
THE ADVANCES THAT IT’S DONE IN BEING ABLE TO KEEP PEOPLE OUT OF THE HOSPITAL WHICH IS
THE LOW HANGING FRUIT FOR COST AND BEING ABLE TO MANAGE THAT, PHYSICIANS ACROSS THE COUNTRY
ARE VERY INTERESTED IN CONTROLLING DRUG PRICES AS EVERYONE KNOWS, AS ARE WE I ALSO THEN WOULD
ASK A LOT OF QUESTIONS ABOUT WHETHER PEOPLE FELT LIKE THEY WERE COMFORTABLE TAKING RISK
AND I FOUND A COUPLE OF ANSWERS. ONE WAS PEOPLE KNEW OF A BUNCH OF PRACTICES
THAT HAVE DONE FULL CAPITATION WAY BACK 15 YEARS AGO AND WENT UNDER.
AND THEY’RE VERY NERVOUS ABOUT THAT. AND THE PRACTICES WHO WERE SUCCESSFUL TAKING
CAPITATION NOW HAVE DONE SIGNIFICANT CARVE OUTS, THEY’VE CARVED OUT THE DRUGS AND CARVED
OUT THOSE THINGS THAT THEY CANNOT MANAGE, AND THOSE ARE THE ONES THAT HAVE SUCCEEDED
IN CAPITATED RISK MODEL. SO WHEN I CREATED THE MASON IDEA, I PUT A
FOUR% RISK WITHHOLD ON THE MEETING THE QUALITY METRICS OF THE–ALL OF THE ENM CODES SO THE
RISK THERE AND IF A PHYSICIAN DOES NOT PROVIDE THE QUALITY OF CARE, THEY LOSE MONEY AND THAT’S
SIGNIFICANT RISK, I BELIEVE. WE CARVED OUT THE DRUGS AND PAID THEM AT INVOICE
PRICE, AND WHEN WE SPOKE BEFORE YOU SAID HOW WILL THAT BRING DRUG PRICES DOWN?
AND AS I THINK ABOUT IT, AS WE LEARN THAT IF THE DRUGS ARE CARVED OUT SO WE STILL HAVE
A TARGET WE NEED TO MEET, WE DEFINITELY HAVE AN INCENTIVE TO USE A LOWER PRICE DRUG IF
THERE IF HAS AN EQUIVALENT OUTCOME. AND IT DOES NOT CAUSE MORE DOWN STREAM COSTS
TO MANAGE GIVE THAGOREAN DRUG MORE VISITS TO THE HOSPITAL, MORE VISITS TO THE OFFICE,
ET CETERA. WELL WE DON’T HAVE THAT DATA NOW AND WE NEED
IT TO HAVE MORE TRANSPARENCY. PRACTICE PHYSICIANS HAVE TOLD ME THEY’RE NOT
READY TO BE THROWN INTO THE POOL AND LEARN TO SWIM WHEN THEIR PRACTICE IS AT RISK.
I HAVE 180 EMPLOYEES WHO MOZ JOB DEPENDS ON MY PRACTICE SURVIVING AND A WHOLE LOT OF PATIENTS
WHO DEPEND ON ME BEING THERE AND WHAT I FOUND IS THAT THE PATIENT, PRACTICES THAT WERE WILLING
TO TAKE TWO SIDED RISK ARE EITHER THOSE WHO HAVE A DEEP POCKET BEHIND THEM TO MANAGE IT
IF THEY HAD A BAD YEAR, SORE PEOPLE WHO FELT THAT THEY HAD BEEN SO EXPENSIVE AT THE BEGENERATEDDING
THAT THEY’VE DROPPED THEIR HOSPITALIZATION RATE DOWN LOW.
I’M THE ONLY COME HOME PRACTICE THAT HIT A POSITIVE UPDATE AND THE WAY HIT A POSITIVE
UPDATE WAS THAT I SPENT A LOT OF THAT MEALS MONEY HIRING PEOPLE TO GO THROUGH THE CHARTS
AND LABEL THE HCCS AND THEN HARRAIGNINGING MY DOCTORS INTO DICTATING ON THEM AND BILLING
ON THEM. WHICH MEANT THAT I SPENT MONEY THAT SHOULD
HAVE BEEN ON IMPROVED PATIENT CARE ON CHANGING HO YOU WE DOCUMENT AND IT DOESN’T CHANGE THE
CARE BUT IT DID RAISE MY TARGETS ENOUGH THAT I COULD SLIDE UNDER IT AND THE OTHER WAY I
HIT A POSITIVE PHARMACOKINETICS AND SIN THAT WE HAD A COUPLE PATIENTS, JUST A COUPLE WHO
HAD HORR END US DIABETIC LEG ULCERS ENDED UP IN A SNF AND GOT THEIR DIABETIC ING ELSERS
TREATMENT AND I TELL YOU THIS BECAUSE WE DON’T WANT TO MODEL
THAT TELLS ME THE WAY TO SUCCEED AT THIS IS IF I TAKE THE PEOPLE WHO ARE MORE SICK AND
I SEND THEM OFF TO SOMEONE ELSE TO TAKE CARE OF, THAT’S CRUST WRONG.
WE DON’T WANT TO MODEL THAT REWARDS ME FOR USING A LESS EFFECTIVE CHEMO THERAPY BECAUSE
IT’S CHEAPER AND I’LL HIT A TARGET. WHAT WE DO WANT IS A MODEL THAT ACCURATELY
PAYS US, THAT TAKES ALL THE PATIENTS CONSIDERATIONS IN, PUTS ALL THIS STUFF TOGETHER, COMES UP
WITH THE PRICE TAG THAT HAS REASONABLE FOR GIVING OPTIMAL CARE, AND THAT’S WHAT WE TRY
TO CREATE WITH MASON. AS I TALK TO PEOPLE AROUND THE COUNT RADIOY
ABOUT THE MASON MODEL, ONE OF THE REACTIONS I GOT OVER AND OVER AGAIN WAS THIS WOULD TEACH
US HOW WE CAN ACCEPT TWO SIDED RISK. THIS WOULD TEACH US HOW WE CAN HAVE AN ACCURATE
PRICE TAG. HOW WE CAN TAKE THAT COST, MANAGE TO THAT
COST, HAVE THE TRANSPARENCY OF SEEING THE MEDICARE CLAIMS DAILY BASIS THEA AS THEY COME
IN SO IT’S THE DAY THE CLAIM IS DROPPED AND THAT LETS ME KNOW IF THIS IMAGING CENTER CAN
HAVE THES MORE THAN THAT KNOW THAT IMAGING CENTER, IF THIS HOSPITAL COSTERS MORE ON A
DAY RATE THAN THE OTHER HOSPITAL, THAT LETS THE ONCOLOGIST OF ANY ILK OF ONCOLOGIST MANAGE
THAT PATIENT VERY EFFECTIVELY. SO THE RISK SHOULD BE ON QUALITY.
THERE IS A SHARED SAVINGS PART OF THIS WHERE WE PAY IT BACK AND WE BANDED TOGETHER THIS
GROUP OF PRACTICES TO POOL FOR REINSURANCE. REINSURANCE YOU CAN POOL FOR, SO THAT WE CAN
MAKE IT SO THAT IF WE HAVE A PARTICULARLY BAD YEAR, ADVERSE SELECTION, WHOLE BUNCH OF
PEOPLE WITH DIABETIC LEG ULCERS THAT I DON’T TREAT VERY EFFECTIVELY BECAUSE I DON’T DO
THAT THEN AT LEAST WE WON’T LOSE THE PRACTICE, PEOPLE WON’T LOSE THEIR JOBS AND CANCER PATIENTS
WON’T LOSE THEIR DOCTORS SOPHISTICATEDY WE NEED TIME TO LEARN HOW TO DO THIS, WE NEED
TO USE THE 21ST CENTURY IDEAS OF DATA SCIENCE, TO LOOK AT CLAIMS DATA AND CLINICAL DATA AND
PUT THEM TOGETHER IN ACCURATE TARGETS CARVE OUT THE DRUGS.
I WILL TELL YOU PHARMA HAS BEEN CALLING ME, BECAUSE THEY’RE VERY WORRIED THAT THEIR DRUG
WILL NOT LOOK FAVORABLY ON THEIR PATHWAY. AND I TELL THEM, THAT IF YOU’RE DRUG IS MORE
EFFECTIVE AND LESS EXPENSIVE AND LESS TOXIC IT WILL SHOW UP ON THE PATHWAY AND I THINK
THAT’S WHAT WE’RE AFTER. AND THE RISK SHOULD BE BASED ON THE QUALITY
OF CARE THAT I GIVE, NOT ON FACTORS OUTSIDE OF MY CONTROL.
THANK YOU.>>THANK YOU.
>>ONE OTHER THING IS I AGREE THAT WITH WITH THE PROCESS OF GOING TO PTACH WHICH TOOK OVER
A YEAR AND WAS VERY INTENSIVE, AND THEN TO COME AND DISCOVER THAT THERE IS NO MECHANISM
FOR FUNDING THOSE PROJECTS THAT DIDN’T SURVIVE THE PTAC GAUNTLET THAT I THINK YOU’RE MISSING
GRAYIT OPPORTUNITY THERE. I THINK THERE’S REMARKABLE THINGS, I THINK
MASON S&P GOOD, PRIDE OF AUTHORSHIP ISSUE EVERYONE I TALK TO THINKS IT’S A GREAT IDEA
BUT THERE ARE OTHER PTAC PROPOSALS THAT MADE IT LIEU THAT WOULD HAVE BEEN A GOOD SAVINGS.
WE’RE A BIG COUNTRY, ONE SIZE MAY NOT FIT ALL.
WHAT WORKS FOR MY LAB FIZZIST WILL NOT WORK AS WELL ON THE NAVAHO NATION.
SO IF WE CAN HAVE OPTIONS TO DO THAT, IF YOU CAN TRY A WHOLE BUNCH OF THINGS THEN WE WILL
COME UP WITH A SERIES OF THINGS THAT COULD REALLY CHANGE THE COST OF CARE AND QUALITY
OF CARE ACROSS THE COUNTRY. THANK YOU.
>>THANK AND YOU DR. MCIN ARE VERY MUCH FOR ALL THE THINKING YOU’VE DONE.
NOT ALWAYS AN EASY CONVERSATION BUT WE DO APPRECIATE IT AND I WANT TO SAY SOMETHING
I THINK TO THE EXTENT THAT PEOPLE HAVE IDEAS BUT HOW WE COULD AND SOME OF OUR MODELS WE
HAVE TRACKS, WE’RE TALKING ABOUT TWO LEVEL RISK TRACKS THAT FOLKS SEE TO USE THE TOOLS
TO PUT THEM TOGETHER, WE REALLY WELCOME THAT PART OF THE CONVERSATION AND HONESTLY, SO,
WE CAN MAYBE THINK ABOUT HOW WE CAN USE A LOT OF FREIGHT THINKING GOING ON, PUTTING
ASIDE THINGS THAT MAY BE BEYOND WHERE I CAN BE RIGHT AT THIS MOMENTENT, I THINK IT’S WELCOME
AND LET’S CONTINUE TO HAVE THAT CONVERSATION.>>AARON [INDISCERNIBLE] FROM ONCOLOGY I WANT
EMPHASIZE THE GRATITUDE FOR THAT’S BEEN EXPRESSED FOR NOT ONLY HOLD THANKSGIVING SESSION TODAY
BUT PROVIDING AVENUES FOR OPEN COMMUNICATION THROUGHOUT THE PAST FIVE YEARS OR THREE YEARS AT
LEAST REGARDING YOU KNOW OUR EXPERIENCE AND OCM AND OUR CONCERN FOR WHAT’S GOING TO COME
NEXT. SO WE’VE, YOU KNOW LEARNED THROUGHOUT THE
PAST FEW YEARS THAT 60-70% OF TOTAL COSTS OF CARE IS IN PHARMACEUTICALS.
SIXTY-70% TOTAL COST OF CANCER CARE IS IN PHARMACEUTICALS.
IT’S THE MOST IMPORTANT ISSUE IN HOW YOU ALL ARE GOING TO EVALUATE COST PERFORMANCE RELATIVE
TO APPROPRIATE VERSUS INAPPROPRIATE USE OF PHARMACEUTICALS IS THE MOST CRITICAL ASPECT
OF BOTH OF OCM AND ONCOLOGY CARE FIRST. WE’VE SEEN IN OUR DATA THAT USE OF THE EXPENSIVE
IMMUNOTHERAPYS ARE VERY CLOSELY TIED TO OVERTARGET EPISODE SPENDING.
SO THERE HAS TO BE A MECHANISM FOR CMMI TO ACCOUNT FOR APPROPRIATE VERSUS INAPPROPRIATE
USE OF THIS EXTREMELY EXPENSIVE AGENTS THAT ARE DOING INCREDIBLE THINGS FOR A LOT OF PATIENTS
WHO ARE–WHO ARE RECEIVING THEM. SO, I THINK THAT KIND OF BETS TO THE REMARKS
WE WANT TO MAKE AROUND RISK. WHICH IS A TERM THAT I THINK HAS BEEN USED
TOO LOOSELY. BECAUSE I’M NOT A CLINICIAN, I COME FROM A
FINANCE EDUCATIONAL BACKGROUND. WHAT WE’VE TALKED ABOUT AS RISK IS NOT IN
FINANCE WHAT WE REFER TO AS RISK, FINANCE WHAT WE REFER TO AS RISK IS SOMETHING FOR
THE COIN, YOU KNOW THE NEXT CARD DEALT IN BLACKJACK.
WHAT WE’RE TALKING ABOUT IS UNCERTAINTY ABOUT THE COST OF THE FUTURE STANDARD OF CARE FOR
OUR PATIENTS. SO, THAT’S UNCERTAINTY, IT’S DIFFERENT THAN
RISK, IT’S NOT–IT’S AN UNCERTAINTY ABOUT A FUTURE STATE THAT WE CANNOT PREDICT AND
THEREFORE IT’S NOT THE SAME, YOU KNOW TAKING ON TWO SIDED RISK DOESN’T MEAN THE SAME THING.
IT’S NOT LIKE THIS IS A RISK WE CAN CALCULATE AND THEN UNDERSTAND HOW WE NEED TO BE COMPENSATED
FOR TAKING THAT RISK WHEN WE HAD HAD THIS FOUNDATIONAL UNCERTAINTY ABOUT WHAT THE FUTURE
STANDARD OF CARE FOR CANCER PATIENT SYSTEM GOING TO COST.
SO NOW I’LL KIND OF TRY TO ADDRESS SOME OF YOUR MORE DIRECT QUESTIONS ABOUT WELL WHAT
DO RISK TIERS LOOK LIKE. AND THE WAY WE DISCUSS THEM SO FAR.
WELL, YOU KNOW AGAIN IN FINANCE ANYTIME WE LOOK AT TAKING ON ADDITIONAL RISK, WE HAVE
TO LOOK AT WHAT IS THE RISK PREMIUM. WHAT IS THE–YOU KNOW HOW DOES THAT MARGINAL
BENEFIT FOR TAKING ON NET INCREASED RISK TAKE ON THE AMOUNT WE’RE TAKING ON WE TALK ABOUT
THE MPP OMOUNT WILL BE, WE IT HAS TO PRACTICE REDESIGN THAT YOU KNOW WE TALKED ABOUT EARLIER,
ALL OF THE IMPORTANT WORK THAT SOCIAL CARE–SOCIAL WORKERS AND DIETITIANS AND PSYCHOLOGISTS ARE
DOING HA HAS TO–IT HAS TO FUND STOP LOSS INSURANCE, THAT’S GOING TO COME OUT OF THIS,
WHATEVER THAT MPP IS. AND NOW, BETWEEN THE DETUCKIBLE THAT WE WOULD
ACTUALLY BE FORCED TO PAY AND WHATEVER IS LEFT THAT CONSITUTES THAT RISK PREMIUM I THINK
THAT’S WHERE WE CAN LOOK AT WHAT AN APPROPRIATE RISK LEVEL LOOKS LIKE, BECAUSE IF WE CAN OOH
DENTIFY ALL RIGHT, AFTER WE PROVIDE ALL OF THE PRACTICE REDESIGN ACTIVITIES THAT WE’RE
GOING TO BE REQUIRED TO DO, YOU KNOW AS WELL AS ALL THE ENMS AND YOU KNOW ALL THE POETIC
AT ANY TIMIA WILY IMAGING AND LAB, OKAY, NOW, WHAT IS LEFT AS A PREMIUM FOR POTENTIALLY
HAVE TO HAVING TO PAY MEDICARE BACK. BECAUSE IF THIS WILL BE A VOLUNTARY PROGRAM,
A LOT OF PRACTICES WILL JUST SAY WHY WOULD YOU TAKE ON THIS UNCERTAINTY OF NOT KNOW WAG
THE FUTURE STANDARD OF CARE AND CANCER CARE WILL COST.
THERE HAS TO BE A PREMIUM THERE, AND I THINK THAT’S THE WAY TO LOOK AT HOW FAR–HOW DRASTIC
THE RISK SHOULD POTENTICALLY-SHOULD POTENTIALLY DROP IN TERMS OF A POTENTIAL PAY BACK.
SO AISLE LEAVE TO ASK QUESTIONS? , I WAS GOING TO POINT OUT THAT IA LOT OF
MODELS WE’VE BEEN TALKING ABOUT LATELY AND WE HAVE SOME OF THAT HERE ISA THE ASINET RICK
RISK WHERE THERE’S LESS DOWN SIDE THAN UPSIDE SO, AND I DON’T–I KNOW THIS IS SOMETHING
WE’VE SEEN USED IN SEVERAL OTHER INNOVATION CENTER MODELS, AND IT’S SOMETHING THAT ARE
JUST RECENTLY PRIOR DIRECTOR ADAM BOWLER WAS VERY COMMITTED TO LOOKING AT CREATING A LOT
OF ASYMMETRIC RISKS SO THERE WAS MORE UPSIDE THAN DOWN SIDE SO I THOUGHT I WOULD THROW
IT OUT AND SEE–YOU KNOW AGAIN HOW YOU THINK ABOUT THAT, THE NUMBERS ACTUALLY, YOU KNOW
ARE PRETTY CONSEQUENTIAL THERE, RIGHT? BECAUSE LET’S TAKE THE OCM EXAMPLE WHERE YOU
HAVE TWICE AS MUCH POTENTIAL UPSIDE AS DOWN SIDE RISK.
YOU’RE TALKING ABOUT A PRACTICE ENDING LEVEL OF RISK AT THE DOWN SIDE AND YOU’RE TALKING
ABOUT AN ASTRONOMICALLY HIGH, YES, TWICE AS HIGH UPSIDE, BUT THAT’S NOT A NUMBER ANYONE’S
GOING TO HATE SO IT DOESN’T–IT’S NOT OF CONSEQUENCE.>>FEELS TOO UNREAL.
>>RIGHT.>>SO WE’RE NOT–
>>SCARY.>>WE’RE TALKING ABOUT THE BAND OF ACTUAL
OUTCOMES THAT THE OVERWHELMING MAJORITY OF PRAPBLGTISS OR WERE NEVER LIKELY TO SEE, YOU
KNOW YOU’RE NOT LOOKING AT THIS TWICE AS HIGH AS–IT DOESN’T END UP–THAT ISN’T HOW THE
DECISION ANALYSIS AT A PRACTICE LEVEL IS GOING TO WORK.
>>THANK YOU.>>HI, THANK YOU WE WANTED TO OFFER RECOMMENDATIONS
ON THE PROPOSED PRICING MODAND HE WILL WHAT IT MIGHT LOOK LIKE IN OCF IF THE INFORMAL
RFI THAT CAME OUT ON FRIDAY, THERE WAS AN IDEA AROUND HAVING A CANCER SPECIFIC TREND
FACTOR IN A CANCER SPECIFIC NOVEL THERAPY ADJUSTMENT, AFTERWAY WOULD STRONGLY SUPPORT
HAVING A CONSER SPECIFIC NOVEL ADJUSTMENT, NOVEL THERAPY ADJUSTMENT AS WELL AS TREND
FACTOR. YOU KNOW HAVING A SINGLE TREND FACTOR AMONG
ALL CANCER TYPES CREATING ADVANTAGES OR DISADVANTAGES AT THE PRACTICE LEVEL WHEN GIVEN ONCOLOGY
PRACTICE IS MIX OF CANCER PATIENT SYSTEM NOT THE SAME MIX AS THAT OF THE THE NATIONAL LEVEL
AS WELL AS NOT STAYING THE SAME ON A YEAR TO YEAR BASIS.
AND THEN FROM A NOVEL THERAPIES PERSPECTIVE, THESE ARE JUST NOT CONSISTENTLY OR UNIFORMLY
COME ON TO THE MARKET ROLLLY. WE BELIEVE THAT IN ORDER TO SUCCESSFULLY USE
CANCER SPECIFIC TREND FACTORS OR NOVEL ADJUSTMENT THERAPY OR NOVEL THERAPY ADJUSTMENTS THAT
THE COOL VARIANTS IN THE MOLL MODEL NEED TO BE BETTER CALIBRATED AND OUR ANALYSIS OF 20
OCM PRACTICES WE FOUND THAT SOME ATTRIBUTES ARE SLAWED AND THAT THEY’RE TOO STRONGLY CORRELATED
WITH STRONGER WEAK PERFORMANCE BASED PAYMENT INSTEAD OF PRICE, SO FOR EXAMPLE, HAVING RADIATION
THERAPY FOR EXAMPLE, SHOULD THEORETICALLY GIVE YOU A HIGHER PRICE BUT IT SHOULD NOT
STRONGLY CORRELATE WITH A POSITIVE PERFORMANCE BASED PAYMENT WHICH IS WHAT WE HAVE FOUND
IN OUR NARCSINAL SIS. AS ANOTHER EXAMPLE, WE FOUND THAT LUNG CANCER
STRONGLY CORRELATES WITH NEGATIVE PERFORMANCE BASED PAYMENTS WHICH AGAIN POINTS TO A PLAY
IN NAFACTOR. YOU KNOW CURRENTLY IN OCM TODAY, CMS USES
ONE REGRESSION MODEL ACROSS ALL THE DIFFERENT–ALL THE DIFFERENT CANCER TYPES ONE AT THE LEVEL,
CMS HAS A BUNDLE IN EACH ADVANCED AND IF THERE IS INSUFFICIENTIA DATA FOR LOW VOLUME CANCERS
TO HAVE THEIR OWN RETPREGZ, WE WOULD RECOMMEND THOSE LOW VALIUM CANCERS WITH RELATIVELY SIMILAR
CANCER TYPES. ADDITIONALLY WE WOULD RECOMMEND CMS AT LEAST
EVALUATE USING ACCS AS CO VARIANTS IN THE PRICING MODEL AGAIN SIMILAR TO HOW THE SPECIFIC
WEIGHTS ARE USED TO RISK ADJUST BPI TARGET VANCEED PRICES AND SEE IMPACT OF SPECIFIC
CO-MORBIDITIES, ON PREDICT THE SPENDING VARIES GREATLY BOTH AMONG INDIVIDUAL HCCS AS WELL
AS APPLIED TO DIFFERENT BUNDLES JUST AS AN EXAMPLE FOR HCC NINE, LUNG CANCER AND HCCTEN
LYMPHOMA, THE IMPACT OF THOSE HCCS ON THE SEPSIS BUNDLE VARIES SIGNIFICANTLY AND THE
IMPACT OF THOSE HCC,OT PNEUMONIA BUNDLE VARIES EVEN FURTHER.
WE WOULD ALSO SUPPORT THE ADJUSTMENTS OF THE MONTHLY POPULATION PAYMENT FIST ARE CANCER
TYPE AS WELL AS WHETHER THE PATIENT RECEIVED CHEMO OR HORMONAL THERAPY.
BUT JUST WITH REGARDS TO THE RECRUITMENT, IT WOULD BE HELPFUL FOR CMI TO PROVIDE DETAILED
CLAIMS DATA FOR BOTH THE ATTRIBUTED AND THE NONATTRIBUTED PATIENTS WHO RECEIVE CARE FROM
THAT PROVIDER TO HELP PRACTICES VALIDATE WHY PATIENTS ARE GETTING TO DIFFERENT PROVIDERS.
IN THE RFI THERE WAS AN IDEA TO HAVE MULTIPLE RISK LEVELS, ENCLOUDING AN UPSEDENTARY ONLY
AND VERSUS DOWN SIDE, YOU WOULD CERTAINLY SUPPORT THE OPTION FOR PARTICIPANTS TO PICK
A DIFFERENT RISK LEVEL AND REALLY IMPORTANTLY, WITH REGARDS TO THE CONCEPTUALIZED RISK ARRANGEMENT
WE WOULD RECOMMEND THAT THIS IS NOT PENALIZED HISTORICALLY THOSE WHO HAVE BEEN PARTICIPATING
IN OCM. THANK YOU VERY MUCH FOR YOUR TIME.
>>HI, NICK FROM PEIN, N MEDICINE AGAIN, I WILL ECHO THE LAST COMMENTS THAT THE ADJUSTMENTS
ARE CAREFULLY CONSIDERED SO THAT THE GOALPOSTS AREN’T MOVED FURTHER FOR OCM PRACTICES IN
THE TOP HALF AND I THINK THAT’S BECAUSE REPRESENTING A HOSPITAL BASED SYSTEM, HOSPITALS IN GENERAL
ARE VERY COB SERVAATIVE WHEN IT COMES TO RISK, WE GET MORE ATTENTION PAID TO THE RECRUITMENTS
SMALL AS THEY MAY BE THAN TO POSITIVE PERFORMANCE BASED PAYMENTS, IT COULD BE 20 TIMES THE OPPOSITE
DIRECTION AND FOR THAT REASON, I SUGGEST MAYBE CONSIDERING A ONE SIDED RISK MODEL, BUT WITH
PERHAPS BENEFITS BEING HEAVILY WEIGHTED IN CMS FAVOR EVEN IF THERE WAS NO POSSIBILITY
OF US EARNING A PBP UNDER CURRENT FOAMANCE IT WOULD ALLOW A CONSERVATIVE MINDED RISK
AVERS ORGANIZATION TO PARTICIPATE AND RECRUIT BENEFITS FROM CMS FAVORITE WHEN IT COMES TO
CARE TRANSFORMATION, LASTLY, FOR FOR CONSIDERATION IS HOW LONG MIGHT IT TAKE FOR THE MPPTO CAP
UP TO SIGNIFICANT CHANGES IN A PRACTICES PRACTICES OR PRACTICE SIZE?
BECAUSE HAVING TO FLOAT THAT EXPENSE OVER THE CURRENT 18 MONTHS RECONCILIATION PERIOD
WOULD BE DIFFICULT.>>I THINK IT’S NOT CAREER.
AND WE TALKED A LOT ABOUT THAT AND WOULD BE OPEN TO IDEAS THERE, THERE ARE A FEW DIFFERENT
WAYS THAT WE TALKED ABOUT POTENTIALLY TRYING TO BE AS NIMBLE AS POSSIBLE ESPECIALLY ON
THE VOLUME FRONT. AND SO, WOULD LOVE IDEAS OF HOW WE CAN DO
THAT TO MAKE SURE THAT PARTICIPATING PRACTICE WOULDN’T HAVE A CASH FLOW PROBLEM.
>>I THINK WOULD BE INCLUDED SERVICES THAT WILL TAKE
TIME.>>WE EVALUATION PROCESS DITTANILY HAVE TO
TAKE THAT INTO CONSIDERATION BUT EVEN JUST KHAEUFPLING PRACTICES IN GENERAL EMPLOY IN
TERMS OF THE TIMING OF DATA HAVE KNOW ABOUTY ARE PETEEDLY SAID HERE IS SOMETHING TO KEEP
INTO CONSIDERATION AS YOU MOVE FORWARD’M I BEING THIS IS SMART BECAUSE
THIS WILL BE CRITICAL TO THE TOTAL TRANSFORMATION OF ONCOLOGY CARE IN GENERAL BECAUSE IT’S PART
OF AND INTOPERATING THEM WILL BE A POSITIVE THING BUT I KNOW TRUSTEES’ A LOT OF DIFFERENT
REPRESENTATIONS OF HEALTH SYSTEMS AND PRACTICES AND COMMUNITY IS ALL THAT BRING INTO THOSE
FACTORS AND THERE’S ALL THESE DIFFERENT PRICE POINTS THAT YOU HAVE TO COME INTO PLAY, AS
WELL AS LOGISTICS BUT THAT POINT I THINK WILL REALLY BE HELPFUL MOVING FORWARD.
BUT THAT WAS MY POINT FOR A SMALLER GROUP THAT WOULD CRIPPLE THEM FOR SURE.
>>SO [INDISCERNIBLE] WITH U.S. ONCOLOGY AND TEXAS ONCOLOGY AGAIN, ABOUT THE MPP, ONE THING
I WOULD REQUEST IS THAT WE HAVE THE ABILITY FOR PRACTICE IS INTERESTED WE COULD FIND A
LETTER OF INTENT AND GIVE THIS INFORMATION UPFRONT SO WE CAN PERSPECTIVELY MAKE SURE
THAT THE INFORMATION KEEPS US WHOLE WHICH IS YOUR INTENT IS TO KEEP THIS WHOLE ON THE
ADMINISTRATIVE CHARGES BECAUSE A LOT OF CONCERNS THAT HAVE BEEN SAID ARE READY IT FIND OUT
FOR A MODEL WITHOUT WHAT THEY’RE GOING TO BE AND I GET A PERSPECTIVE VALIDATE THAT AND
ONOON ONGOING BASIS EVERY SIX MONTH WE HAVE TO VALIDATE THAT FOREVER BEFORE I SIGN UP
FOR THE NEXT SYNTH MONTH TOWARD, I THINK IT WOULD BE ALLEVIATE A LOT OF CONCERNS AND WITH
THAT, AND IT ALLOWS US TO PLAN A BIT. IF WE START SEEING CASE MIXES THAT COME IN,
AND EXPECTED BECAUSE THERE ARE SOME MONEY OR ANTICIPATES MACHINEY MONEY FROM IT WAS
VERY HELPFUL, AND AND WITH THE WAY IT MAY VARY QUITE A BIT, MAY BE HELPFUL FOR THEM
TO HAVE A PLAN IF THEY KNEW LAWN MOWER IT WAS GOING INTO THE MODEL, VERSUS WAITING TO
GET THE FIRST PAYCHECK WOULD BE VERY HARD AND THEN ALSO, JUST FOR THE MPP AS WELL, IF
YOU DO HAVE A PAY BACK, MAKE SURE YOU ALLOW PRACTICE AS TIME TO PAY THAT BACK.
BECAUSE AT THE END OF THE DAY, MY NURSES, MY SOCIAL WORKERNS, ALL MY OTHER STAFF, GET
PAID REGARDLESS, THE PHYSICIANS ARE ONES WHO TAKE THE OWENESS OF HAVING PAY BACKS TO THAT
END, PHYSICIANS TAKE THE BENEFIT OF GETTING ADDITIONAL MONEY IN, BUT IT’S HARD TO TELL
THEM AND KEEP THEM EMPLOYED AND TELL THEM IF A CAN’T GET A PAYCHECK FOR A MONTH, I WOULD
CAUTION ON THAT AS WELL, ON THE RISK IMMEDIATELE, I LOVE THE FACT THAT YOU’RE TAKE SPWOG ACCOUNT
THE TREND FACTOR BASED ON CASE MIX, THE NOVEL THERAPY, THOSE ARE HUGE STEPS FORWARD, DEFINITELY
WANT MORE DETAILS ON THAT, I MEAN OBVIOUSLY YOUR DETAILS ARE FAIRLY LIMITED ON THAT, I
WOULD LOVE MORE DETAILWHAT YOU’RE THINKING AND MY QUESTION FOR YOU ARE WE GOING TO HAVE
A CHANCE TO COMMENT AGAIN ONCE YOU GET MORE DETAILS BACK?
THIS PROPOSAL SEEMS LIMITED BUT WITH THE COMMENTS THAT IS RECEIVED WE WILL GET TO HAVE,A DITIONAL
COMMENT, HAVE YOU THOUGHT ABOUT IT YET? THAT IS AN EVOLUTIONARY PROCESS AND WE WILL
TAKE THAT FEEDBACK, WE KNOW PEOPLE WOULD LIKE AN OPPORTUNITY TO SEE MORE AS WE GO ALONG
AND IT IS THE REASON WE SORT OF STOPPED AND HAVE THIS SESSION AND THE ABILITY FOR PEOPLE
TO SEND IN FEEDBACK, WE DIDN’T WANT TO GET TOO FAR TOWN THE ROAD AND NOT HAVE AN OPPORTUNITY
AND WE CAN TAKE THAT AS WE TALK ABOUT HOW THE DAY WENT, IT SOUBDED TO ME LIKE A LOT
OF MORE TECHNICAL DETAILS IN THE PAYMENT METHODOLOGY AND OPPORTUNITY TO SORT OF WEIGH IN ON THAT
AND WHAT IT MIGHT LOOK LIKE AND WE CAN INCLUDE THATS WE GO FORWARD.
>>THAT WOULD ISSUE APPRECIATED.>>JUDGE I WOULD JUST SAY FOR OTHERS BECAUSE
I KNOW ASHLEY AND OTHERS MENTIONED INTEREST THAT AS WELL, WE ARE TRYING TO BALANCE–BECAUSE
WE HAVE TIME TO TAKE AN APPLICATION AND SO WE YOU KNOW TIME STARTS EVAPORATING QUICKLY.
>>I APPRECIATE THAT. IT GOES TO THE RISK, IF I’M EXPECTED TO GO
INTO TWO SIDED RISK BECAUSE WE’RE GOING TO BE A TWO SIDED RISK, WELL WE ARE NOW, IF I
HAVE TO ANY IS INTO RISK RIGHT AWAY WITHOUT FULLY UNDERSTANDING WHAT THE RISK IS, IT’S
SCARY BUT IF I HAVE A POTENTIAL GOING INTO A ONE SIDED RISK MODEL BEFORE I MAKE THAT
JUMP BACK, IT’S HELPFUL TO MAKE SURE THAT WE DO THAT.
I LOVE THE COMMENT THAT WAS MADE EARLIER ABOUT THE CAPITATED MODEL BY ESSENCE IS A RISK MODEL
BECAUSE YOU’RE TAKING RISK ON THOSE TRADITIONAL FEE FOR SERVICE METHOLOGYS AS WELL I DON’T
KNOW IF YOU CAN TELL THAT TO YOUR HIGHER UPS BUT IT IS SEEKING CAPITATION AND THAT WOULD
BE MY CONCERN AS FAR AS MOVING RIGHT INTO A RISK BASED MODEL WITHOUT HAVING ADEQUATE
TIME TO ADDRESS THAT.>>I THINK THE OTHER THING I WOULD POINT OUT
IN GENERALLY IN TRYING TO HIT THE TIME FRAME AND EVERYTHING ELSE, I FEEL LIKE WE THIGHED
HARD WITHIN THE SCOPE OF BEING THE FEDERAL GOVERNMENT TO BE AS RESPONSIVE AS WE CAN BE
WHEN THINGS HAVE COME UP FROM PRACTICES AND IT’S ALSO THAT WE NEVER LOOK AT THESE PARTICULAR
MODELS AS BEING A ONE TIME DOWN ON THE GROUND. WE HAVE OBVIOUSLY LISTENED TO ALL THE TECHNICAL
FEEDBACK THAT’S COME BACK ON THE TREND FACTOR BECAUSE WE DO THESE ANALYSIS FIGURE OUT HOW
TO ADJUST THEM AND SO,OOSE QUITE POSSIBLE WE WILL COME BACK WITH A HERE’S THE FIRST
YEAR, SECOND YEAR AND THERE’S SOMETHING WE CAN’T GET TO BECAUSE I THINK THE CONTINUITY
IS REALLY IMPORTANT TO US FOR PEOPLE WHO HAVE MADE AN INVESTMENT AND WANT TO CONTINUE WORKING
IN THIS SPACE IT’S REALLY IMPORTANT SO JUST, THERE ARE LOTS OF WAYS WE LOOK AT FIGURES
OUT THE STAGE.>>AND THAT’S MUCH APPRECIATED.
>>LIKE LOOKS LIKE I WOULD HAVE THE LAST WORD, I AM [INDISCERNIBLE] AND I WANT TO HIGHLIGHT
TWO PARTS, GOING BACK TO RISK PRACTICE I WANT GO [INDISCERNIBLE] JOB APPLICANTS BECAUSE
IN THE THREE EXAMPLES YOU LOOK AT THE MORTALITY RATE IN THE U.S., PART OF THE COUNTRY IS 3.6
PER THOUSAND, OTHER PAF OF 12,000, AND IT IS SECOND THING S&P WITH THE SECURITY IS AREYALATED
TO THE HIGHEST RISK AND MORTALITY. AND THE SWROEP CODE–ZIP CODE COULD BE PART
OF YOUR SOCIAL DEMOGRAPHIC AND ECONOMIC RISK FACTORS COULD BE QUITE SIGNIFICANT.
LET SECOND POINT IS YOU MA I WANT TO MAKE AN ARGUMENT THAT IF YOU CHOOSE NOT TO GO FOR
OCF, IN THE MIDSTRIKE HAVE YOU NINE PERSON DOWN SIDE RISK ALREADYY WHICH PART OF THE
WHOLE EQUATION. SO, IF YOU DON’T RECALL ALL THE EQUALITY MEASURES,
IF YOU DON’T HAVE EHR, IF YOU OVERSPENT THEN COME 2022, THE PRACTICE WILL BE WONDERFUL
NEAR NINE PERSON DOWN SIDE RISK ANYWAY, SO EITHER OF THE WAY YOU CHOOSE, YOU WILL FACE
SOME SORT OF DOWN SIDE OR UPSIDE IN THE POTENTIAL AND IF YOU EQUATE RISK FROM THE OCF, TAKE
NINE% OF THE NONDRUG PAYMENT, YOU COULD ACTUALLY HAVE LARGER METHODOLOGY, THIS MAY NOT BE TOO
HARD TO TELL BUT YOU’RE UPSIDE OF GETTING [INDISCERNIBLE].
AND THEN IDEALLY WANT TO THANK YOUR TEAM AND I THINK LAURA, SARAH, ALEX, AS WELL AS [INDISCERNIBLE]
AND WE ENJOYED WORKING WITH YOU AND WE’VE SEEN THE PATIENT CARE BEING TRANSFERRED AND
WE WANT TO CONTINUE DOING THAT. THANK YOU.
>>OKAY, YEAH? [INDISCERNIBLE].
WHEN I LOOK AT KIND OF WHAT WE’VE LEARNED FROM OCM, I THINK A COUPLE THINGS COME TO
MIND IN TERMS OF BOTH MANAGING RISK AND PRICE. SO ONE, I THINK BEING ABLE TO LOOK AT TUMOR
TYPES AND IN A MORE GRANULAR FASHION, I THINK IS INCREDIBLY IMPORTANT, THERE THERE’S OBVIOUS
LOAMACYY A DATA CHALLENGE THRU ABOUT THERE’S STILL ADDITIONAL THINGS THAT CAN BE DONE TO
TRY TO ESSENTIALLY SOME SUGMENTORSHIP SKILL TUMOR TYPES THEREFORE PRICES CAN BE PREDICTED
MORE ACLIGHTLY, SO THAT’S KIND OF ONE BROAD COMMENT AND I THINK THERE’S AGAIN, LIMITATIONS
ON THE DATA SIDE BUT I THINK THERE’S STILL ADDITIONAL WORK THAT CAN BE DONE SO THE CONCRETE
EXAMPLE,INE TPR*EPBSS CAN BE DRAWN IN THE ADWHERE YOU GENT TREATMENT FOR BREAST CANCER
TRYING TO SUBSEGMENT BREAST INTO LIKE A SUBSECTION OF THOSE TYPES OF CLINICAL STATES IS REALLY
WHAT I WOULD LIKE, WHAT I’M HOPING WILL BE AT LEAST A BASIS FOR THIS NEXT MODEL.
THAT WILL ALSO HELP GUIDE THE DATA INTO THE CLINICAL SIDE AND EPROSES, IT’S THE CLINICAL
FRAMEWORK ON PRACTICALLY SUBSEGMENT TUMOR TYPES THAT CAN HELP GUIDELINE ADHERENCE THE
DEVELOPMENT OF THE MODEL. THE SECOND KPHEBT WHERE I SEE KIND OF UNMODELLED
RISKS SO TO SPEAK, I THINK IT’S VERY DIFFICULT SUBJECT IS HOW TO CHARACTERIZE DISEASE PROGRESSION
AND THIS IS SOMETHING–THIS IS A SUBJECT WHICH I THINK IS MUCH LARGER THAN CMS, IT’S HARD
TO [INDISCERNIBLE] CMS AGAIN, BUT SOME THINGS ARE, AND AS CANCER IS TURNING INTO MORE OF
LIKE A CHRONIC CONDITION OR PSEUDOCHRONIC CONDITION, THIS ISSUE OF DISEASE PROGRESSION
IS WHAT DOMINATES TREATMENT AND RISK, OCCUPY FORTUNATELY STAGE SUGGEST NOT DESIGNED TO
CHARACTERIZE CROSS SECTIONAL CLINICAL STATUS. I KNOW YOU GUYS ARE OBVIOUSLY COLLECTING APPROXIMATE
A VARIABLE CLINICAL STATUS ALREADY BUT IT’S OBVIOUSLY NOT A VERY GRANULAR VARIABLE.
AND I THINK THIS IS AN AREA WHERE CMS IN PARTNERSHIP WITH THE CANCER COMMUNITY COULD PROVIDE LEADERSHIP
TO TRY TO MOVE THE FIELD FORWARD AND CHARACTERIDESSING WHAT THE IS THE RIGHT FRAMEWORK WE HAVE TO
CHARACTERIZE CURRENT CLINICAL STATUS BECAUSE THIS ISSUE WILL BE WHAT DOMINATES RISK, COST
AND OTHER PATHWAY GIVES RAMSTERSA ACCIDENT ROUND ONCOLOGY BECAUSE PATIENTS FORTUNATELY
THANK WILL GOODNESS ARE LIVING LONGER WITH THEIR DISEASE IN BETWEEN STATES OF INITIAL
DIAGNOSIS AND CURE. THAT’S WHERE A LOT OF INTENSITY IN RESOURCE
ALLOCATION GOES.>>HELLO THIS IS RYAN [INDISCERNIBLE] FROM
FLAT IRON HEALTH, WE ARE A SPECIFIC EHR VENDOR SO I WANT TO BRING A BIT OF A DIFFERENT PERSPECTIVE
FOR JUST A QUICK MINUTE. I WAS INVOLVED IN THE ORIGINAL TEAM THAT HELP
BUILD A SOLUTION AND ADAPT OUR EHR TO SUPPORT PRACTICE IN THE [INDISCERNIBLE] TODAY, IT
TOOK US YOU KNOW SIX MONTHS OF MANNING PLUS ANOTHER SIX MONTHS OF BUILDING AND ENGINEERING
WORK TO ACTUALLY GET A CARE PLAN IN THE EHR AND DEVELOP WORK FLOWS THAT MADE SENSE TO
COLLECT DATA FOR THE QUALITY MEASURES THAT YOU’RE ALL SUPPORTS TODAY INCLUDING FOUR AND
FIVE FOR PAIN AND DEPRESSION RESPECTIVELY. I AM ENCOURAGED TO YOU KNOW YOU ARE GOING
TO USE THOSE GOING FORWARD, BECAUSE WE HAVE A MECH NIM FOR THOSE TO, WO.
I WOULD BE ENCOURAGED TO SEE YOU THINK ABOUT YOU HO YOU CAN INVOLVE THE HR VENDORS AND
CONVERSATIONS STARTING TODAY. WE PLAN TO COLLABORATE ON COMMENTS, WE’RE
PARTICULARLY ENCOURAGED BY THE USE OF EPROS BECAUSE WE’VE BEEN THINKING ABOUT HOW WE ACTUALLY
CAN BUILD THOSE INTO THE POINT OF CARE, STARTING NEXT YEAR, SO THAT’S GENERALLY ALIGN WIDE
OUR PLANS, BUT IT’S MORE SERENDIPITY THAN ANYTHING PLANNED, I GUESS, SO, YOU KNOW TO
THE POINT YOU CAN KEEP THE EMR EHR, KIND OF VENDOR SESSIONS CONTINUING AND GET US ALL
IN THE SAME ROOM AND,A HRAO*EUPBED ON YOU HOW WE CAN SUPPORT PRACTICES IN THIS MODEL
AND INCENTIVIZING US TO DO THINGS OF THE POINT OF CARE IS GREAT.
I KNOW WHAT ITIC TAKEN–THEYS TO THINGS UPON AND WE WANT TO AHRAO*EUFRPBED WITH THE PAYMENT
MODELS, 52 PRACTICE IN THE OCM TODAY, IT’S GOING TO BE A MUCH LARGER PORTION OF OUR NETWORK
IN 2021, SO, AND WE’RE ALREADY PLANNING A ROADMAP FOR 2020 NOW.
SO THE SOONER YOU CAN GETTOUS AROUND THIS TODAY, THE BETTER IT IS FOR US TO PLAN.
BECAUSE WE HAVE COMPLETING PRIORITIES INCLUDING OTHIS, NC’S FLOCKING OF RULE RIGHT NOW BEFORE
THANKSGIVING.>>NO INFORMATION ON THAT!
? YEAH, YEAH, I KNOW SO JUST THINK ABOUT THE
WORLD KIND OF WHOLISTICALLY BUT WE REALLY APPRECIATE THE COLLABORATION TO DATE.
IF YOU THINK THE COLLABORATION OF EHRS THAT STARTED A BIT INTO THE OCM INSHALLLY THAT
WOULD BODE WELL FOR BOTH US OF THE EMR, HR PRACTICES CAN THANK YOU.
>>ONE THING ON TIME SUGGEST WE HAVE TO MAKE SURE WE COMPLETE UNFORTUNATELY OVER WHATEVER
ALL OF OUR INTERNAL PROES ISS AT SOME POINT BEFORE WE CONCLEAN HAVING, SO TO KNOW THAT
WE HAVE 82IT A BIT OF A WAYS TO GO HERE, WE’RE NOT SO FAR ALONG AND THAT WAS THE POINT OF
HAVING A CONVERSATION BUT WE WILL DEFINITELY BE MINDFUL.
I KNOW YOU DID A LOT WITH THE EHAD, VENDORS AT THE BEGINNING.
>>THANKS. APPRECIATE THAT.
>>AARON FROM ONE OLGICOLOGY. I WAS UNCOURAGE INDEEDLET INTRODUCTION THAT’D
MIN STRAIGHTER EMPHASIZED PATIENTS OVER PAPERWORK AND SO THAT’S A PRIORITY FOR CMMI, YOU KNOW
I THINK IT’S IMPORTANT TO ACKNOWLEDGE THAT ALL THE ADDITIONAL DATA THAT GETS COLLECTED
IN THESE MODELS IS YOU KNOW HUMAN RESOURCE TIME, IN ADDITION TO TECHNOLOGY EEXPENSE,
SPECIFICALLY SHE PHEBGZED WAIVERS AVAILABLE TO PARTICIPANTS IN CMMI MODELS TO KIND OF
CIRCUMVENT ADMINISTRATIVE BURDEN AND ADMINISTRATIVE RESTRICTIONS, WE’VE FOUND THAT THOSE IN MY
EXPERIENCE, OUR EXPERIENCE THOSE WAIVERS ARE INCREDIBLY DIFFICULT TO TAKE ADVANTAGE OF,
SO IF THERE’S ANYTHING THAT COULD BE DONE TO MAKE THAT LANGUAGE STRONGER THORS MAKE
THE USE CASES MORE CLEAR AS TO WHAT’S INTENDED, WE HAVEN’T–IT’S JUST–IT’S INTERESTING TO
ME, THAT THAT’S–IT WAS A POLICY INTENTION CLEARLY THAT WE HAVE NOT BEEN ABLE TO TAKE
ADVANTAGE OF BECAUSE WHEN IT COMES TO COMPLIANCE AND LEGAL REVIEW, THE LANGUAGE IN NOSE WAIVERS
HAVE NOT PROVIDED FOR THE REMOVAL OF THE BARRIERS THAT WE’VE WANTED TO ACCOMPLISH.
SO. I JUST WANT TO SEE IF THAT’S SOMETHING YOU
ALL COULD LOOK AT.>>CHRIS WAS JUST ASKING IF WE HAVE SPECIFIC
EXAMPLES FROM YOU, I HAVE HEARD THIS FROM OTHERS AARON BUT IF YOU CAN SEND US EXAMPLES
IN YOUR EXPERIENCE, THAT WOULD BE HELPFUL.>>YEAH, I’LL–WE’LL DO THAT IN DETAIL IN
OUR COMMENT LETTER.>>GREAT.
SO WE ONLY HAVE FIVE MINUTES BUT I WANT TO MAKE SURE I’M NOT SURE WE MADE IT, WE DID
TALK ABOUT MULTIPAYER AND HOPDS I WANT TO MAKE SURE THERE WERE ANY LAST WORDS OR ANYTHING
THATY DIDN’T TALK ABOUT, SOMEBODY JUST CAN’T HELP JUMPING UP AND SAYING SOMETHING ABOUT,
WE WOULD WELCOME THAT. INCLUDING ON THE PHONE.
WE’RE GOOD? OKAY?
WELL THEN, THANK YOU SO MUCH MUCH FOR MAKING THE TREMENDOUSLY DOWN HERE, READING THINGS
ON SATURDAY MORNING AND FOR CONTINUING TO PARTNER WITH US.
IT’S THE MOST IMPORTANT PART OF WHAT WE DO WITH WHAT YOU DO, NONAPOPTOTIC THE WHAT WE
DO SO THANK YOU AGAIN FOR COMING. [APPLAUSE ]

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