President Donald J. Trump’s executive order to roll back initiatives on diversity, equity, and inclusion (DEI) has swept across federal health programs large and small—agencies have been cut or eliminated across HHS, and hundreds of research grants have been canceled.1,2
Although the executive order itself was signed with great fanfare, implementation has been a quieter process. Now, it turns out that CMS has dropped key health equity elements of the Enhancing Oncology Model (EOM),3 the successor to an oncology alternative payment model (APM) that was largely left alone during the first Trump administration.
When it was announced June 27, 2022, the EOM incorporated the Biden administration’s priorities for health equity: Practices would be required to collect data on social determinants of health as well as health-related social needs (HRSNs) and come up with plans to address them.4,5
Now, it seems, health equity plans are canceled.
CMS has not publicly announced this shift. Earlier this month, a spokesperson dodged a direct question about the future of HRSN reporting in an email to The American Journal of Managed Care® (AJMC®).
However, according to a leader in value-based care, the change is contained in revised agreements sent to EOM practices.
“HRSN screening has not been removed from the program,” said Lalan Wilfong, MD, senior vice president for value-based care at Thyme Care, in an email to AJMC. “However, CMS will not require or accept submissions of health equity plans in EOM for 2025 and beyond, which was a previous requirement for the program.”
“The CMS Innovation Center will remain transparent regarding changes to advance its mission to lower costs and improve quality of care. The Center looks forward to sharing information about next steps, including its new strategic vision, modifications to models to improve their potential for certification and expansion, and new models that empower Americans to live healthier lives while protecting taxpayers.”
CMS statement to The American Journal of Managed Care
In addition, CMS has amended data collection requirements for social determinants of health on a go forward basis, starting this spring. CMS made these changes through “a 2025 unilateral amendment” to existing EOM agreements. Practices were told that “this unilateral amendment to the agreement is to comply with Executive Order 14151 and Executive Order 14168, effective January 20, 2025,” Wilfong said.
CMS Claims Transparency and “Strategic Vision” to Come
AJMC submitted questions to CMS about the EOM, including one that asked the agency to state its position on tracking HSRNs going forward. In a response received April 11, 2025, the agency said, “The CMS Innovation Center will remain transparent regarding changes to advance its mission to lower costs and improve quality of care. The Center looks forward to sharing information about next steps, including its new strategic vision, modifications to models to improve their potential for certification and expansion, and new models that empower Americans to live healthier lives while protecting taxpayers.”
Separately, CMS published a bulletin March 4, 2025, rescinding a Biden administration guidance that addressed HSRN efforts in Medicaid.6 However, earlier bulletins discussed the use of Medicaid and the Children’s Health Insurance Program (CHIP) to cover services such as housing and nutrition supports. The new bulletin states that HRSN services in Medicaid will be evaluated on a case-by-case basis.7
EOM Replaced Oncology Care Model
There are similarities between Oncology Care Model (OCM), which ran from 2016 to 2022, and the EOM, which launched July 1, 2023.3 Both required enhanced services, such as navigation and advanced care planning, and both evaluated metrics gathered in 6-month blocks called Performance Periods. Practices that outperformed certain benchmarks during the period could receive a portion as “shared savings.”
But there were some important differences: at the start of EOM, monthly payments for each patient being treated for cancer dropped from $160 to $70, although CMS would pay an extra $30 for patients also enrolled in Medicaid. EOM only focused on 7 major cancer types, limiting the universe of affected patients. The EOM required “downside risk” at the outset, which meant if a practice failed to achieve savings benchmarks it would have to pay Medicare.3 When uptake of the EOM was much lower than the OCM, leaders of the CMS Innovation Center revised the baseline monthly payment to $110 and adjusted the risk formulas to give practices more breathing room.8
On February 28, 2025, CMS let practices in the EOM know how they fared in Performance Period 1, and some managed service organizations (MSOs) have shared topline results (See Related Article).
Practices Invested in Health Equity, HRSN Reporting
Unlike the OCM, the EOM introduced tracking of HRSNs, which required practices to screen patients for problems finding food, housing, and transportation and come up with plans to address these challenges.3 Although HRSN initiatives are distinct from those related to DEI, a 2024 report from CDC showed that HRSNs are more prevalent among Black and Hispanic adults than those who are White.9
This raised concerns among those with a stake in the EOM, given the wide net cast by the Trump administration as it eliminates DEI efforts across government. Individual practices and MSOs, as well as some payers, have invested in addressing health equity generally and HRSNs specifically.
Over 2 years ago, EOM participant Tennessee Oncology appointed its first medical director for health equity and community engagement.10 McKesson, which supports the largest number of EOM participants through The US Oncology Network, announced in January 2025 that CMS had renewed its status as a Qualified Clinical Data Registry, and its statement touted the implementation of a new measure that tracked how well practices resolved HRSNs.11
Will Models Be Mandatory?
Discussion of making Medicare oncology models mandatory started in the first Trump administration, when then–HHS Secretary Alex Azar told attendees at a 2018 conference that the time had come for “exploring new and improved episode-based models in other areas, including radiation oncology.”12 The resulting Radiation Oncology (RO) Model was hotly debated during the COVID-19 pandemic, and its implementation was delayed by rulemaking in 2022.13
During Azar’s tenure, discussions arose about mandatory models in medical oncology with the development of the Oncology First Model, which ultimately focused on bundled payments. Oncology Care First never launched, because the upheaval of COVID-19 compelled CMS to extend the OCM for a year beyond its scheduled 2021 expiration.14 By 2022, the Biden administration had arrived, and the focus shifted to addressing health equity.15
Concerns have flared anew, following a January 7, 2025, article by CMS leadership that hinted EOM could be mandatory in the future.16 The lead author, Alexandra Chong, PhD, is a veteran CMS Innovation Center official who served in both the first Trump administration and the Biden administration.
In response, authors from Tennessee Oncology warned in an op-ed that mandatory models could pose serious risks for small and rural practices. Start-up costs for APMs are significant, they wrote, and imposing them on practices with fewer resources could cause some practices to not accept patients who require complex care.17
So far, Wilfong said, rumors of mandatory models are just that. “CMS has not made any official announcements about making EOM mandatory,” he said. “What we do know is that policymakers are increasingly focused on value-based payment structures across health care, including oncology.”
Thyme Care, which has partnered with AON on EOM implementation, is “well positioned” for any shift, he said. “Regardless of whether participation becomes mandatory, the fundamental principles of high-quality, cost-effective care will remain constant, and we're committed to continuing our leadership in this space.”
CMS Touts Changes, July Enrollment
Biden administration officials unveiled the EOM on June 27, 2022, days before the OCM expired with 122 practices still enrolled.3,18 Fewer providers signed on to the EOM in its first year; just 44 practices participated, of which 36 remain (1 has dropped since January).3,19
As oncology leaders waited for EOM’s design in 2022, many expected smaller monthly payments after an independent report found the OCM did not save money.17 However, leaders told CMS that the cuts went too far; when combined with a reduction in the number of covered cancers and a more uncertain risk schematic, too many practices worried they would end up repaying Medicare. In addition, the EOM added the HRSN requirement without any additional compensation; CMS officials at the time noted that providers received larger monthly payments for patients who were also enrolled in Medicaid.3
The low uptake prompted changes. Starting January 1, 2025, EOM practices receive higher monthly payments under more favorable risk formulas. A new round of providers will start the EOM in July, and the model will now run to 2030.19
In their email, officials from CMS keyed on the prospect of more practices and patients benefiting from the model.
“CMS looks forward to welcoming a second cohort of model participants in July 2025,” the email said. Officials touted the new payment structure and promised more changes are on the way.
“In adding a second cohort of participants, extending the model, and updating payment policies, more patients undergoing cancer treatment and their families will have access to the enhanced services offered under the model, and more members of the oncology community will be able to help CMS shape the future of cancer care.”
Highlights of Early EOM Performance
CMS confirmed that EOM practices received early data from Performance Period 1; these were characterized as “preliminary reconciliation results.” As CMS waits to release full results, some numbers have trickled out: The US Oncology Network shared in a LinkedIn post that 12 practices achieved $44 million in gross savings for Medicare, “while delivering exceptional, high-quality care to EOM patients.”20
“This early success is a testament to the dedication and expertise of the participating practices,” the post stated. “As we continue to innovate and strive for excellence in oncology care, we’re encouraged by the positive impact this will have on patient outcomes and health care efficiency.”
AON, with a total provider population about one-tenth the size of The US Oncology Network, touted $6 million in Medicare savings (see Related Article).
“Our first performance period in the EOM yielded a positive outcome, validating our approach to value-based cancer care and demonstrating the strength of our leadership team, clinic staff, and partnership with Thyme Care,” AON Chief Medical Officer Stephen “Fred” Divers, MD, said in an email. “This achievement reinforces AON’s leadership in alternative payment models, and we’re excited to implement new strategies to further enhance our performance in future performance periods.”
References
New Research Challenges Assumptions About Hospital-Physician Integration, Medicare Patient Mix
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Varied Access: The Pharmacogenetic Testing Coverage Divide
February 18th 2025On this episode of Managed Care Cast, we speak with the author of a study published in the February 2025 issue of The American Journal of Managed Care® to uncover significant differences in coverage decisions for pharmacogenetic tests across major US health insurers.
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What's at Stake as Oral Arguments Are Presented in the Braidwood Case? Q&A With Richard Hughes IV
April 21st 2025Richard Hughes IV, JD, MPH, spoke about the upcoming oral arguments to be presented to the Supreme Court regarding the Braidwood case, which would determine how preventive services are guaranteed insurance coverage.
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