If you received chemotherapy in Georgia between 2016 and 2022 — or if you work at a Georgia oncology practice that participated in or considered the model — you lived through what was, at the time, the most ambitious Medicare experiment in cancer care delivery in U.S. history. That model was the Oncology Care Model (OCM).
OCM was the CMS Innovation Center's first major voluntary oncology bundled payment model, the foundational predecessor to today's Enhancing Oncology Model (EOM). OCM ran from July 1, 2016 through June 30, 2022 — a six-year voluntary performance period that enrolled approximately 200 oncology practices and 17 commercial payers nationwide. OCM transformed how community oncology delivered care: it funded patient navigators, after-hours triage lines, advance care planning conversations, palliative-care integration, survivorship plans, and care coordination across the cancer episode. OCM produced billions of dollars in care-transformation investments. But it ultimately under-saved Medicare in net terms — leading directly to the EOM redesign that took effect July 1, 2023.
For Georgia, OCM matters historically because the state's largest oncology practices participated throughout 2016-2022 and built the patient-navigation, after-hours, advance-care-planning, and palliative-integration infrastructure that still defines Georgia community oncology today. Emory Winship Cancer Institute (NCI-designated), Northside Hospital Cancer Institute (the single highest-volume community oncology in Georgia), Piedmont Cancer Institute, Georgia Cancer Specialists, Wellstar Cancer Network, Augusta University Georgia Cancer Center (NCI-designated), Atrium Health Navicent Cancer Center in Macon, and Memorial Health Curtis & Elizabeth Anderson Cancer Institute in Savannah were among the Georgia practices that participated in OCM at various points. The operational practices established under OCM — named navigators per patient, 24/7 oncology nurse access, integrated palliative consults from week one, advance-care-planning conversations documented in care plans — became standard of care across Georgia oncology practices regardless of OCM participation status.
This guide walks Georgia oncology beneficiaries, families, practice leaders, navigators, billing teams, and policy stakeholders through every component of OCM's history: the statutory foundation, the six-year performance period, the seven performance periods, the 13 cancer types, the six-month episode structure, the $160 PBPM MEOS payment, the two-sided risk track with upside-only on-ramp, the three quality domains, the Performance-Based Payment reconciliation, the Advanced APM treatment, and the operational transformation OCM drove. We also examine why OCM under-saved Medicare and what specific design choices EOM changed in response.
What OCM was: the statutory and regulatory foundation
OCM rested on a four-layer statutory and regulatory stack:
Section 1115A of the Social Security Act (42 U.S.C. § 1315a) — the CMMI statutory framework — gives the Secretary of HHS authority to test innovative payment and service-delivery models. Added by Section 3021 of the Patient Protection and Affordable Care Act (Public Law 111-148, March 23, 2010), Section 1115A is what enabled CMS to launch OCM as a voluntary model without going back to Congress. OCM was one of the first major Section 1115A specialty-care models.
The OCM Final Notice and Request for Applications (February 12, 2015) defined OCM as a voluntary, five-year (later extended to six-year), two-sided risk oncology model with 13 cancer types, six-month episodes, $160 PBPM MEOS payments, an upside-only initial risk arrangement with two-sided opt-in, multi-payer alignment, and Advanced APM eligibility for two-sided participants. Practice applications were due June 2015; the six-year performance period began July 1, 2016.
Section 1833(z) of the Social Security Act — added by MACRA 2015 (Public Law 114-10, April 16, 2015), Title I, Section 101 — established the Advanced APM framework. OCM's two-sided risk track qualified as Advanced APM. OCM's one-sided risk track (the initial upside-only on-ramp) did NOT qualify.
The 340B Drug Pricing Program — Section 340B of the Public Health Service Act — interacted with OCM because most major Georgia cancer centers participating in OCM were 340B-eligible covered entities. 340B drug acquisition pricing changed the economics of chemotherapy episode total spend in ways CMS analytics had to account for.
These four authorities — Section 1115A SSA, ACA Section 3021, the OCM Final Notice/RFA, and Section 1833(z) SSA via MACRA — defined everything about how OCM operated for six years.
When OCM ran: performance periods
OCM had seven performance periods over six calendar years:
- Performance Period 1 (PP1): July 1, 2016 – December 31, 2016 (six-month transition)
- Performance Period 2 (PP2): January 2, 2017 – June 30, 2017
- Performance Period 3 (PP3): July 1, 2017 – June 30, 2018
- Performance Period 4 (PP4): July 1, 2018 – June 30, 2019
- Performance Period 5 (PP5): July 1, 2019 – June 30, 2020 (COVID-19 onset)
- Performance Period 6 (PP6): July 1, 2020 – June 30, 2021 (COVID-affected, performance adjustments)
- Performance Period 7 (PP7): July 1, 2021 – June 30, 2022 (final, one-year extension)
OCM was originally planned as a five-year model ending June 30, 2021. CMS extended OCM by one year through June 30, 2022 to (a) allow more time for EOM design, (b) provide continuity through COVID-era cancer care disruptions, and (c) give OCM participants more performance-period data for final reconciliation.
Who participated: oncology practice eligibility and the 200-practice cohort
OCM enrolled approximately 200 physician group practices (PGPs) nationwide. To participate, a practice had to:
- Bill Medicare Part B for systemic chemotherapy administration
- Meet minimum cancer episode volume thresholds
- Commit to delivering enhanced services
- Have data infrastructure for OCM reporting requirements
- Sign a CMS-practice participation agreement
OCM was also a multi-payer model: 17 commercial payers signed multi-payer alignment agreements, meaning OCM-participating practices received aligned MEOS-style payments not just from Medicare but from major commercial payers in their regions for episodes covering the same 13 cancer types. This multi-payer dimension was unusual for CMMI demonstrations and provided important coherent-incentive validation for participating practices.
The 200-practice OCM cohort represented a wide cross-section of U.S. oncology: academic medical center oncology programs (Emory Winship, MD Anderson satellite practices, etc.), large community oncology networks (US Oncology Network, Texas Oncology, Florida Cancer Specialists), independent community oncology practices, and hospital-employed oncology arms of integrated delivery systems.
For Georgia, participating practices over the OCM lifespan (varying by performance period) included some combination of Emory Winship, Northside Hospital Cancer Institute, Piedmont Cancer Institute, Wellstar Cancer Network, Georgia Cancer Specialists, Augusta University Georgia Cancer Center, Atrium Health Navicent Cancer Center, and Memorial Health Curtis & Elizabeth Anderson Cancer Institute. Specific OCM participant lists are published by CMS Innovation Center.
What OCM covered: the 13 cancer types
OCM covered 13 cancer types, much broader than EOM's eventual seven:
- Breast cancer
- Lung cancer
- Prostate cancer
- Colorectal cancer
- Lymphoma
- Multiple myeloma
- Bladder cancer
- Cervical cancer
- Endocrine cancers (thyroid, adrenal, others)
- Gastric cancer
- Head and neck cancers
- Liver and pancreatic cancers
- Other cancers (catch-all for less common types)
The 13-cancer-type scope captured the vast majority of Medicare chemotherapy episodes nationally. The breadth was operationally meaningful for practices: any chemotherapy patient at an OCM practice with one of 13 diagnoses triggered an episode and generated MEOS payments.
The EOM successor narrowed to seven cancer types based on OCM's data analysis: CMS found that some less common cancers had insufficient practice-level volume to make benchmarking statistically stable, and that some included cancers had highly variable treatment pathways that produced benchmark noise rather than meaningful efficiency signals.
For Georgia, the 13-type OCM scope captured Georgia's high-incidence cancer burden: lung, breast, prostate, and colorectal cancers (all top-five Georgia cancer diagnoses) plus lymphoma, multiple myeloma, head and neck, and others. Atlanta-area academic medical center oncology programs, which see substantial volume across all 13 types, benefited from the broad scope.
Episode structure: the six-month chemotherapy episode
OCM's fundamental unit was the six-month episode, structurally similar to EOM's later six-month episode.
Episode trigger: initiation of systemic chemotherapy administration for one of the 13 cancer types. Identified via Part B claims for chemotherapy administration codes (J-codes for drugs, administration codes for infusion/injection).
Episode duration: 180 days from the trigger.
What was included in episode total spend:
- Chemotherapy drugs (Part B)
- Chemotherapy administration (Part B)
- Office visits and E&M (Part B)
- Imaging and labs (Part B)
- Radiation therapy (Part B)
- Inpatient admissions (Part A)
- Outpatient hospital services (Part B)
- Skilled nursing facility (Part A)
- Home health (Part A)
- Hospice (Part A)
- DME (Part B)
- Part B oral chemotherapy
- Part D oral chemotherapy spend (separately calculated)
Multiple concurrent episodes: allowed across different cancer types.
Subsequent episodes: a new chemotherapy regimen more than 180 days after prior trigger initiated a new episode.
This episode structure (six months, all Part A + Part B, chemotherapy administration trigger) carried forward essentially unchanged into EOM.
MEOS: $160 PBPM Monthly Enhanced Oncology Services
OCM paid participating practices a Monthly Enhanced Oncology Services (MEOS) payment of $160 per beneficiary per month (PBPM). This was the headline OCM payment.
OCM did NOT differentiate MEOS by dual-eligibility status (this differentiation was introduced later in EOM, which pays $70 PBPM non-dual and $100 PBPM dual-eligible).
MEOS was paid monthly throughout each beneficiary's six-month episode. For an OCM practice with 1,000 active episodes at any given time, MEOS generated approximately $160K per month — meaningful enhancement-services funding.
MEOS was intended to fund (and largely did fund):
- Patient navigators — typically nurse or social-worker navigators assigned per patient panel
- 24/7 after-hours triage lines — oncology nursing access for side-effect management
- Advance care planning conversations — structured documented conversations about goals of care
- Palliative care integration — early palliative referrals from week one
- Care coordination — communication with primary care, surgical oncology, radiation oncology
- Patient-reported outcomes — symptom and functional status surveys
- Survivorship care plans — end-of-treatment plans for follow-up surveillance
- Care plan documentation — structured Care Plan documentation required by OCM
MEOS did NOT enter the episode total spend calculation. It was a separate enhancement-services payment, paid on top of fee-for-service.
The MEOS rate of $160 PBPM was set at OCM launch based on actuarial analysis of expected enhancement-services costs. EOM later reduced this to $70-$100 PBPM based on CMS analysis that:
- Some enhancement services overlapped with services already billable under standard FFS
- Some MEOS-funded activities had insufficient impact on outcomes to justify the higher rate
- Practices had achieved economies of scale in enhancement services delivery
Two-sided risk track and upside-only on-ramp
OCM offered participants two risk options:
One-Sided Risk Arrangement (upside-only)
- Initial default for new participants
- Practices earned shared savings if actual spend < benchmark
- No downside risk (no repayment if actual > benchmark)
- NOT Advanced APM under Section 1833(z)
- Practice physicians remained in MIPS
- Most OCM practices remained one-sided throughout
Two-Sided Risk Arrangement
- Optional opt-in
- Two-sided: practices earned savings if under benchmark, owed repayment if over
- QUALIFIED AS ADVANCED APM under Section 1833(z) SSA
- Practice physicians could become QPs, exempt from MIPS, earn 5% APM incentive
- Smaller subset of OCM practices opted in
The two-track structure with optional opt-in into two-sided risk is exactly what EOM changed: EOM is two-sided from day one with no upside-only on-ramp. CMS concluded based on OCM data that the one-sided on-ramp delayed practices' transition to true accountability and undermined the savings case.
Three Quality Domains and Performance-Based Payment
OCM measured practice quality across three domains:
Domain 1: Patient Experience
- Patient experience surveys
- CAHPS-type measures
- Communication, access, care coordination
Domain 2: Process and Documentation
- 13-point Care Plan documentation (ASCO Care Plan elements)
- Patient-reported outcomes collection
- Advance care planning documentation
- Process measures
Domain 3: Clinical Quality
- Hospitalization rates during chemotherapy
- ED visit rates
- Survival metrics
- Hospice use and timing
- Pain management
Each domain produced a score. A composite quality score (combining all three domains) adjusted the Performance-Based Payment (PBP).
Performance-Based Payment (PBP) reconciliation
At the end of each performance period, CMS calculated PBP by comparing actual episode total spend to a benchmark price:
- Benchmark = historical claims-based prediction adjusted for:
- Cancer type
- Stage and clinical characteristics
- Patient demographics and risk
- Regional cost factors
- Trend factor
- Discount factor applied (CMS retained share of expected savings)
If actual spend < benchmark and quality score sufficient → PBP earned (shared savings). If actual spend > benchmark in two-sided arrangement → PBP owed (repayment). Quality score gated retained savings share.
For most OCM practices in the one-sided arrangement, PBP was upside-only — no repayment. This protected practices but limited Medicare's downside protection against over-spending.
Advanced APM status: two-sided risk only
OCM's Two-Sided Risk Arrangement qualified as Advanced APM under Section 1833(z) SSA. Practices in two-sided OCM could have physicians become QPs:
- Exempt from MIPS for the corresponding year
- Historically receive 5% APM incentive payment on Part B professional services
- Subject to QP thresholds (patient or payment)
The One-Sided Risk Arrangement did NOT qualify. Most OCM practices were one-sided throughout, and their physicians remained in MIPS reporting (or APM Performance Pathway if eligible through other arrangements).
The relatively small share of OCM practices in two-sided risk was a key data point CMS used to justify EOM's two-sided-from-day-one design.
Coordination with concurrent programs (historical)
MSSP / ACO REACH overlap (then Pioneer/MSSP)
- Beneficiaries attributed to MSSP ACOs could have OCM episodes at participating oncology practices
- Episode spending counted in both OCM reconciliation and ACO Total Cost of Care
- Reconciliation methodologies adjusted to prevent double-counting
340B Drug Pricing Program
- Most major Georgia cancer centers were 340B-eligible
- 340B drug acquisition was below ASP+6% Medicare payment
- Episode total spend used Medicare claims allowed amounts
- 340B savings remained with covered entities outside the OCM benchmark
- This 340B-OCM interaction was complex and policy-debated throughout OCM
MIPS / Advanced APM coordination
- Two-sided OCM practices: QPs exempt from MIPS
- One-sided OCM practices: physicians in MIPS or APP
Multi-payer alignment
- 17 commercial payers signed OCM multi-payer agreements
- Aligned payment for episodes covering 13 cancer types
- Provided coherent incentives across commercial book of business
- This multi-payer dimension was a major OCM innovation
Why OCM under-saved Medicare: the analytic story
OCM produced billions of dollars in care-transformation investments — navigators, after-hours, advance care planning, palliative integration, survivorship — that improved patient experience and likely reduced unnecessary utilization. But in net terms, OCM did not save Medicare money beyond what it paid out in MEOS plus PBP.
The analytic reasons:
- MEOS at $160 PBPM was generous — paid before any savings were measured, regardless of whether enhanced services drove savings
- One-sided on-ramp protected practices — most practices never accepted downside risk
- Drug-cost growth outpaced practice efficiency gains — Part B chemotherapy drug spending grew substantially during OCM (immunotherapy adoption, CDK4/6 inhibitors, etc.), and practices had limited ability to influence drug-list-price dynamics
- 340B coordination favored covered entities — most large OCM participants were 340B-eligible, capturing 340B margin outside the OCM benchmark
- Risk adjustment imperfections — benchmark methodology struggled to fully account for case-mix complexity, especially with novel-therapy proliferation
CMS's analytic conclusion: voluntary oncology models need to be two-sided from day one, with narrower scope for tighter benchmarking, lower MEOS to reduce upfront giveback, mandatory equity planning, and explicit 340B treatment in policy. EOM operationalized each of these conclusions.
Operational transformation OCM drove in Georgia
OCM's clearest legacy in Georgia is operational: the standard of care for community oncology nationwide shifted during OCM, and Georgia practices participated fully in that shift.
Patient navigators
Pre-OCM (before 2016), most Georgia community oncology practices had limited patient navigation. Navigation, when present, was often informal or limited to specific patient populations.
Post-OCM (by 2022 and continuing), named patient navigators per panel are standard at Emory Winship, Northside, Piedmont, Wellstar, Georgia Cancer Specialists, Augusta University, Memorial Health, and Atrium Navicent. MEOS funded the initial hiring; sustained navigation continues post-OCM under FFS billing for navigation services where available plus practice-borne costs.
24/7 after-hours oncology nurse access
Pre-OCM, after-hours patient calls typically went to a covering physician with limited oncology-specific triage. Post-OCM, dedicated 24/7 oncology-nurse triage lines are standard at major Georgia oncology practices. This drove documented reductions in unnecessary ED visits.
Advance care planning
Pre-OCM, advance care planning conversations occurred ad hoc. OCM required structured documented ACP conversations, integrated into Care Plans. Post-OCM, ACP routines persist as best practice across Georgia oncology practices.
Palliative care integration
Pre-OCM, palliative consults often happened only at end-of-life. OCM incentivized early palliative integration, sometimes from week one of chemotherapy. Post-OCM, Emory Winship, Northside Cancer Institute, and other Georgia academic and community oncology programs routinely integrate palliative care from chemotherapy initiation.
Survivorship care plans
OCM required survivorship care plans at end of treatment. Post-OCM, structured survivorship care plans are standard across Georgia oncology practices.
Care plan documentation
OCM required 13-point ASCO Care Plan documentation. Post-OCM, ASCO Care Plan documentation persists as oncology practice standard.
This operational legacy is OCM's most durable contribution to Georgia cancer care: regardless of OCM's net-savings outcomes, the care patients receive at Georgia oncology practices today is materially better because of OCM's enhanced services requirements.
Worked examples — six Georgia OCM scenarios (historical, 2016-2022)
Example 1: Fulton 65 — Atlanta OCM Breast Cancer at Emory Winship (PP4 2018-2019)
Maria was 65 in 2018, lived in Atlanta (Fulton County), and was diagnosed with HER2-positive breast cancer requiring chemotherapy at Emory Winship Cancer Institute, an OCM participant.
When Emory administered her first chemotherapy infusion in early PP4, her OCM breast cancer episode was triggered. During the episode:
- Emory received $160 PBPM MEOS ($960 total for six months) — funding her navigator, advance care planning, after-hours triage
- Total spend was tracked against the breast cancer benchmark price
- Emory submitted required quality data — Care Plan documentation, patient-reported outcomes, ACP documentation
- Maria's experience: she had a named navigator, called the 24/7 line three times for side-effect management, had a documented ACP conversation in cycle 2, and received an integrated palliative consult in week 4
At PP4 reconciliation in 2020, Emory's actual total spend on Maria's episode and her breast-cancer-cohort episodes were compared to benchmark. If under benchmark and Emory's quality score was sufficient (Emory was at the time in two-sided arrangement), Emory earned PBP shared savings; if over benchmark, Emory owed repayment.
Example 2: DeKalb 70 — DeKalb OCM Lung Cancer at Northside (PP5 2019-2020)
James was 70 in 2019, lived in DeKalb County, and was diagnosed with stage III non-small cell lung cancer. He began concurrent chemoradiation at Northside Hospital Cancer Institute, an OCM participant.
His OCM lung cancer episode triggered when chemotherapy administration began. Total spend included chemotherapy, radiation, supportive care, any inpatient stays, and imaging. Northside received $160 PBPM MEOS and provided James with a thoracic-oncology navigator and integrated palliative care from week one.
PP5 covered most of James's episode, but COVID-19 onset (March 2020) disrupted treatment delivery during the final weeks. OCM PP5 reconciliation incorporated COVID-era adjustments.
Example 3: Cobb 68 — Cobb OCM Colorectal at Wellstar (PP6 2020-2021)
Linda was 68 in 2020, lived in Cobb County, and had stage III colon cancer at Wellstar Cancer Network, an OCM participant in PP6.
She had already had surgical resection (which was not an OCM episode — OCM covered chemotherapy episodes only) and now needed adjuvant chemotherapy. When Wellstar administered her first FOLFOX infusion, her OCM colorectal cancer episode triggered. Wellstar's navigator coordinated with the surgical team and primary care; MEOS funding supported this coordination.
PP6 was COVID-affected. CMS adjusted OCM PP6 reconciliation for COVID-related disruptions to treatment, claims patterns, and benchmark applicability.
Example 4: Worth County 72 — Albany hospital non-participation context
Robert was 72 in 2020, lived in rural Worth County (near Albany). His local Albany oncology practice was NOT an OCM participant. He continued under standard FFS Medicare for chemotherapy. No MEOS, no enhanced services obligation, no episode reconciliation.
Some rural Georgia patients traveled to Atlanta for OCM-participating practices to access OCM's enhanced services. Others remained local under standard FFS.
Example 5: Bibb 75 — Macon OCM Multiple Myeloma at Atrium Navicent (PP3 2017-2018)
Patricia was 75 in 2017, lived in Macon (Bibb County), and was diagnosed with multiple myeloma at Atrium Health Navicent Cancer Center during PP3 (assuming Atrium Navicent was OCM-participating in PP3).
Her OCM multiple myeloma episode triggered at first chemotherapy. $160 PBPM MEOS funded her navigation and ACP. Episode covered 180 days of complex multi-agent myeloma chemotherapy plus supportive care.
Example 6: Hall 60 — Gainesville OCM Prostate at NGMC (PP7 2021-2022 final extension)
Robert was 60 in 2021, lived in Hall County (Gainesville, Atlanta MSA), and had metastatic castration-resistant prostate cancer requiring chemotherapy at Northeast Georgia Medical Center. PP7 (final extension) covered most of his episode.
His OCM prostate cancer episode triggered at chemotherapy initiation. MEOS funded his navigation, advance care planning given metastatic disease, and integrated palliative care.
After OCM ended June 30, 2022, his oncology team transitioned operationally to either EOM participation (if NGMC opted into EOM) or standard FFS with continued enhanced services as practice norm.
14 best practices learned from OCM era for Georgia oncology
- Hire dedicated patient navigators — OCM proved navigators reduce ED visits and unnecessary hospitalizations
- Operate 24/7 oncology nurse triage — dramatically reduces unnecessary ED visits during chemotherapy
- Conduct documented advance care planning — improves goal-concordant care, reduces aggressive end-of-life care
- Integrate palliative care from week one — better symptom management, improved survival in some cancers
- Use ASCO Care Plan documentation standards — durable post-OCM standard
- Collect patient-reported outcomes — actionable symptom and functional data
- Develop survivorship care plans — structured end-of-treatment transitions
- Coordinate with primary care — closed-loop communication during chemotherapy
- Risk-stratify patients — identify high-risk patients for intensive navigation
- Standardize chemotherapy regimens — reduce unwarranted variation
- Optimize supportive care — anti-emetics, growth factors, infection prophylaxis
- Monitor 340B economics — separate from CMMI model economics
- Engage commercial payers for aligned payment arrangements
- Build data infrastructure for episode-level tracking — essential for any future bundled model
14 common issues (historical OCM-era and lessons forward)
- One-sided risk created mis-aligned incentives — fixed in EOM with two-sided-from-day-one
- MEOS at $160 PBPM was generous — reduced in EOM to $70-$100 PBPM
- 13 cancer types had benchmark variability for rare cancers — narrowed in EOM to seven
- 340B coordination was policy-ambiguous — EOM explicit about 340B treatment
- Drug-cost growth outpaced practice efficiency — challenge persists in EOM, addressed via novel-therapy adjustments
- Quality measure complexity (three domains) — EOM streamlined measure set
- Care Plan documentation burden — partially streamlined in EOM
- COVID-19 disrupted PP5-PP7 — required special adjustments
- Practice-level volume variability — affected benchmark stability
- Multi-payer alignment was uneven — EOM does not formally require multi-payer
- Dual-eligible beneficiaries had higher complexity — EOM introduced $100 PBPM dual-eligible boost
- Health equity not explicitly required in OCM — EOM made Health Equity Plan mandatory
- OCM did not save Medicare in net — major driver of EOM redesign
- Operational legacy is durable — enhanced services persist regardless of model
25 frequently asked questions
1. What was the Oncology Care Model (OCM)? The CMS Innovation Center's first major voluntary oncology bundled payment model. Ran July 1, 2016 – June 30, 2022.
2. Was OCM mandatory? No. Voluntary; approximately 200 practices applied and were selected.
3. When did OCM start and end? July 1, 2016 launch; June 30, 2022 sunset (after one-year extension from original 2021 end).
4. How many performance periods did OCM have? Seven: PP1 (six-month transition), then six full PPs through PP7.
5. How many cancer types did OCM cover? 13: breast, lung, prostate, colorectal, lymphoma, multiple myeloma, bladder, cervical, endocrine, gastric, head/neck, liver/pancreas, and "other".
6. How long was an OCM episode? Six months (180 days) from chemotherapy initiation — same as EOM.
7. What was MEOS in OCM? Monthly Enhanced Oncology Services payment of $160 per beneficiary per month, paid throughout the six-month episode.
8. Did OCM differentiate MEOS for dual-eligibles? No. Single $160 PBPM rate regardless of dual-eligibility. EOM introduced the dual-eligible boost ($100 vs $70).
9. What were OCM's risk tracks? One-Sided Risk (upside-only, NOT Advanced APM) and Two-Sided Risk (Advanced APM eligible). Most practices remained one-sided.
10. Was OCM Advanced APM? Only Two-Sided Risk OCM qualified as Advanced APM under Section 1833(z) SSA. One-Sided did NOT.
11. What were the three OCM quality domains? Patient Experience, Process and Documentation, Clinical Quality.
12. Did OCM save Medicare money? In net terms after MEOS plus PBP payouts, OCM did NOT save Medicare money. This finding drove EOM redesign.
13. Which Georgia practices participated in OCM? Verifiable participants over the OCM lifespan included Emory Winship and other major Atlanta-area oncology practices. Specific PP participation varied. Check CMS Innovation Center records.
14. What did MEOS fund? Patient navigators, after-hours triage, advance care planning, palliative integration, care coordination, patient-reported outcomes, survivorship plans, care plan documentation.
15. Did MEOS count in episode total spend? No. MEOS was paid separately from FFS, on top of FFS billing.
16. How was the OCM benchmark calculated? Historical claims-based prediction adjusted for cancer type, stage, demographics, regional factors, trend; discount factor applied.
17. What was OCM's multi-payer dimension? 17 commercial payers signed multi-payer alignment agreements, paying aligned MEOS-style payments for the same 13 cancer types in OCM regions.
18. How did OCM coordinate with MSSP ACOs? Beneficiaries attributed to MSSP could have OCM episodes at OCM practices; spending counted in both, with reconciliation adjustments.
19. How did OCM handle 340B? Most major OCM practices were 340B-eligible. Medicare allowed amounts (ASP+6%) flowed into episode total spend; 340B acquisition savings remained with covered entities outside the benchmark.
20. How did COVID-19 affect OCM? PP5-PP7 included COVID-affected periods with CMS adjustments to reconciliation methodologies, benchmark applicability, and quality measurement.
21. What lessons did OCM teach that shaped EOM? Two-sided from day one; narrower cancer scope (seven vs 13); lower MEOS ($70-$100 vs $160); dual-eligible PBPM boost; mandatory Health Equity Plan; explicit 340B treatment.
22. Did OCM require advance care planning? Yes. Structured documented ACP was a core Process and Documentation requirement.
23. What was the ASCO Care Plan? 13-point cancer care plan documentation standard required under OCM; persists post-OCM as best practice.
24. Did OCM enrollment require patient consent? No. Beneficiaries attributed to OCM practices were automatically enrolled in OCM episodes via attribution rules.
25. What happened to OCM practices after June 30, 2022? Practices either applied to EOM (which launched July 1, 2023, after a one-year gap) or returned to standard FFS Medicare for chemotherapy episodes. Many enhanced services continued under FFS billing or practice-borne costs.
Why OCM matters for Georgia cancer care history and present operations
OCM is the foundation under everything Georgia community oncology does today around chemotherapy episodes. The 200-practice nationwide cohort that participated in OCM during 2016-2022 fundamentally transformed U.S. cancer care delivery: patient navigators, 24/7 oncology-nurse triage, advance care planning, palliative integration, survivorship care plans, ASCO Care Plan documentation. These innovations did not exist at most U.S. community oncology practices in 2015. They are standard everywhere now — including across every major Georgia oncology practice — because of OCM.
OCM also taught CMS what does not work: voluntary models with one-sided risk on-ramps; broad cancer scope without statistical stability; high MEOS without measurement of actual enhanced-services value; uniform MEOS without dual-eligible adjustment; quality measurement complexity; ambiguous 340B treatment. EOM addresses every one of these lessons.
For Georgia oncology practice leaders, OCM history is also operational history: the navigator hire dates at Emory Winship, the after-hours triage line implementations at Northside and Piedmont, the integrated palliative consult workflows at Wellstar and Atrium Navicent, the Care Plan documentation tooling at Georgia Cancer Specialists — these are OCM-era investments that defined how these practices operate today.
For Georgia oncology patients and their families, OCM matters because the navigator who calls you, the after-hours nurse who answers your question at 2 AM, the palliative care consult in week one, the advance care planning conversation in cycle 2, and the survivorship plan at end of treatment — these patient experiences are OCM's legacy.
For Georgia oncology billing, finance, and analytics teams, OCM matters because the data infrastructure built during OCM (episode tracking, benchmark analytics, PBP reconciliation, quality measure submission) is the foundation under EOM operations and any future oncology bundled-payment model.
OCM is the past. EOM is the present. The next oncology model — likely launching sometime in the 2028-2030 window when EOM sunsets — will be the future. Understanding OCM's history is how Georgia oncology practices position for that future intelligently.
Contacts
- Medicare — 1-800-MEDICARE (1-800-633-4227), www.medicare.gov
- CMS Innovation Center (OCM archive) — innovation.cms.gov/innovation-models/oncology-care
- CMS Innovation Center (EOM successor) — innovation.cms.gov/innovation-models/enhancing-oncology-model
- QPP Service Center — 1-866-288-8292 (qpp.cms.gov)
- Palmetto GBA (Jurisdiction J MAC) — 1-866-238-9650
- GeorgiaCares SHIP — 1-866-552-4464
- Medicare Rights Center — 1-800-333-4114
- Atlanta Legal Aid — 404-377-0701
- GA Legal Services — 1-800-498-9469
- 211 Georgia — dial 2-1-1
- Eldercare Locator — 1-800-677-1116
- Acentra Health QIO — 1-844-455-8708
- NCI Cancer Information Service — 1-800-4-CANCER (1-800-422-6237)
- American Cancer Society — 1-800-227-2345
- Community Oncology Alliance (COA) — 202-729-8147 (communityoncology.org)
- ASCO (American Society of Clinical Oncology) — 571-483-1300 (asco.org)
- Emory Winship Cancer Institute — 404-778-1900
- Northside Hospital Cancer Institute — 404-851-8850
Last verified: May 14, 2026 Status: In review Pillar: Medicaid / Medicare (Georgia) Voice: Policy translator