Community Oncology Alliance Expresses Strong Concerns with Enhancing Oncology Model and Submits Recommendations to CMS

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COA Letter to CMS Leadership Notes That Current Structure of the EOM Hurts Chances of Model’s Success, Suggests Significant Changes

WASHINGTON, D.C., UNITED STATES, September 14, 2022 / -- In a formal letter to the Centers for Medicare and Medicaid Services’ (CMS’) Administrator Chiquita Brooks-LaSure and Deputy Administrator Elizabeth Fowler, COA has expressed concerns about the proposed design and implementation of the Enhancing Oncology Model (EOM) and offered suggestions for increasing program participation and success.

As currently structured, practices who participate in the EOM face a high barrier to entry, significant investments, and extreme complications, all with limited enhanced payments and high financial risk. The letter details these concerns and provides concrete recommendations to introduce important safeguards for practices and flexibility for their participation in what is potentially a very lopsided risk arrangement.

- Click here to read the full COA EOM comment letter.

In an ominous indicator of the EOM’s future, a survey of practices conducted by COA in late July 2022 found that less than half (42.6 percent) of Oncology Care Model (OCM) participants plan to participate in the EOM. Of all practices, OCM and non-OCM, just over a third (32.2 percent) said that they plan to participate. Since that survey was conducted, little has been revealed of the EOM that would lead COA to believe that many practices will change their mind without changes to the model.

COA completely committed to oncology payment reform, but we also want the EOM to be successful. With the OCM, COA had over 80 percent of OCM participants in a collaborative effort that shared information on best practices. We have already started a similar collaboration for practices considering participation in the EOM. However, without changes, COA is extremely concerned that the EOM will fail as a demonstration project and as a model that can realistically transform the U.S. cancer care and payment system for the better.

Read the full COA EOM comment letter on the COA website.


About the Community Oncology Alliance: COA is a non-profit organization dedicated to advocating for community oncology practices and, most importantly, the patients they serve. COA is the only organization dedicated solely to community oncology where the majority of Americans with cancer are treated. The mission of COA is to ensure that patients with cancer receive quality, affordable, and accessible cancer care in their own communities. More than 5,000 people in the United States are diagnosed with cancer every day and deaths from the disease have been steadily declining due to earlier detection, diagnosis, and treatment. Learn more at Follow COA on Twitter at or on Facebook at

Drew Lovejoy
Community Oncology Alliance