EOM Model Frequently Asked Questions

How can physician group practices interested in EOM apply?

To apply to participate in EOM, applicants must submit their applications using the EOM Request for Application (RFA) Portal at https://app.innovation.cms.gov/EOM. Submission of the PDF version of this application will not be accepted. Instructions on how to log onto the EOM RFA Application Portal will be available soon on the EOM Model page. The EOM RFA Application Portal will open on July 1, 2024.  All EOM applications must be submitted by 11:59 PM ET on September 16, 2024. CMS may not review applications submitted after the deadline. The second cohort of participants will begin their participation in EOM on July 1, 2025, and CMS wanted to provide adequate time for the second cohort to prepare for model implementation, including time to review historical claims data and the participation agreement.

What is the model performance period for EOM?

Model performance period for EOM started on July 1, 2023, and will end on June 30, 2030. Initially, the model performance period was scheduled to end on June 30, 2028, but it has been extended for two years and will now end on June 30, 2030. As such, each of the EOM’s two cohorts can now participate in the model for an extended period of time: cohort 1, which started on July 1, 2023, for seven years, and cohort 2, which will begin on July 1, 2025, for five years. EOM continues to be a voluntary model for both cohorts of participants for the full duration of the seven-year model test.

Is the second cohort available to new payers?

Yes. Payers are encouraged to apply for the second cohort of EOM. New payers can partner with existing EOM participants in the first cohort as well as potential new EOM participants in the second cohort. The RFA will open on July 1, 2024, and payer applications must be submitted by 11:59 PM ET on September 16, 2024. Interested applicants looking for more information should contact the EOM helpdesk at EOM@cms.hhs.gov.

Why is EOM being extended for two more years?

The model is being extended so that both cohorts will have at least five years to participate in the model test. A seven-year model test will allow all EOM participants to have sufficient time to engage in investments, resources, and learnings to not only implement the model requirements but to plan strategically for potential long-term transformation.

What is a Monthly Enhanced Oncology Services (MEOS) payment?

In addition to Medicare fee-for-service (FFS) billing, EOM participants have the option to bill CMS for an MEOS payment. The MEOS payment is for the care management and coordination of oncology patients with Medicare whose episodes are attributed to the EOM participant. EOM participants are eligible to receive a MEOS payment for furnishing Enhanced Services such as patient navigation and care planning to eligible EOM individuals for each month of every EOM episode attributed to them or for every month of the episode until the individual enters hospice or dies. Beginning January 1, 2025, the MEOS payment will be $110 per beneficiary per month (PBPM) and $140 PBPM for dually eligible individuals.

Will the MEOS payments be the same for Cohorts 1 and 2?

Yes. For cohort 1 participants, the base MEOS payments for all MEOS billed with a date of service on or after January 1, 2025, will be $110 PBPM. This is an increase from the current $70 PBPM base MEOS amount. The MEOS payment amount will also be $110 PBPM for the second cohort of participants.

For episodes involving an individual who is dually eligible for Medicare and Medicaid, CMS pays an additional $30 per dually eligible individual per month. This $30 PBPM amount continues to be excluded from the total cost of care. Therefore, for a MEOS payment billed with a date of service on or after January 1, 2025, the payment amount for a dually eligible individual will be $140 PBPM for cohort 1 participants. Cohort 2 participants will also receive $140 PBPM for dually eligible individuals.

Will current EOM participants be required to reapply to the model?

No, current EOM participants do not need to reapply. They will remain in the model, with a new performance period end date of June 30, 2030. Provisionally accepted participants from cohort 1 who are not currently participating in the model will need to re-apply for EOM.

What is the change to the threshold for recoupment for the performance-based payments and recoupments?

EOM participants owe a performance-based recoupment for a given performance period if their total episode expenditures exceed the threshold for recoupment. For each EOM participant, the threshold for recoupment is calculated as a percentage of the benchmark amount for their attributed episodes. For both Risk Arrangement 1 and Risk Arrangement 2, the threshold for recoupment has been raised from 98% of the benchmark amount to 100% of the benchmark amount. For cohort 1, this change will be effective beginning in Performance Period 4 (episodes initiating on or after January 1, 2025). For cohort 2, the threshold for recoupment will equal 100% of the benchmark amount from the start of their EOM participation (episodes initiating on or after July 1, 2025).

Is there a cap on the number of EOM applicants that CMS will accept for the second cohort?

There is no cap on applications for the second EOM cohort. CMS notes that sufficient participation in the model by EOM participants will be necessary for CMS to be able to detect a meaningful change in Medicare expenditures due to the model test.

Of note, not all applicants are guaranteed participation in the model. CMS will consider factors such as the need to ensure a robust evaluation of the model and the results of program integrity screenings.

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