What is the Enhancing Oncology Model (EOM)?

The Enhancing Oncology Model (EOM) is a voluntary value-based care program that the Centers for Medicare and Medicaid Services (CMS) launched in 2023 for medical oncology practices. Practices that take part must report clinical data to CMS, and that data has to be submitted in the mCODE format, a FHIR-based oncology data standard.

How do practices submit data to the EOM?

Data submissions to the EOM happen through the minimal Common Oncology Data Elements (mCODE), a FHIR-based oncology data standard. mCODE is the only data-submission path CMS specified for the model, so any practice in the EOM must produce mCODE-shaped data and any EHR vendor serving those practices must emit it.

Why did the EOM matter for oncology data standards?

By naming mCODE as the sole submission format, the EOM made structured, interoperable oncology data a condition of participation and therefore a business requirement. That turned mCODE from an optional interoperability layer into regulatory infrastructure and made its adoption self-reinforcing.

How widely adopted is mCODE, the standard the EOM requires?

mCODE, the minimal Common Oncology Data Elements, is implemented at more than 70 institutions across six countries. Because the EOM accepts data only in mCODE, joining the model reinforces adoption of the standard: every participating practice has to produce mCODE-shaped data, and every EHR vendor serving those practices has to emit it.

What is Travis Osterman's connection to the EOM?

Dr. Osterman chairs the mCODE Executive Committee, the body that governs the data standard the EOM's submissions run on. He is a board-certified medical oncologist and clinical informatician, and he leads cancer clinical informatics at Vanderbilt Health, so he works on both the clinical side the EOM regulates and the data-standard side it depends on.

The Enhancing Oncology Model (EOM)

A voluntary value-based care program from the Centers for Medicare and Medicaid Services that made structured data reporting a condition of taking part - and named mCODE as the only format that reporting can take.

Definition

The Enhancing Oncology Model (EOM) is a voluntary value-based care program run by the Centers for Medicare and Medicaid Services (CMS). It is aimed at medical oncology practices, and CMS launched it in 2023. In return for taking part, participating practices must report clinical data to CMS, and that reporting happens in a single specified format: the minimal Common Oncology Data Elements (mCODE), a FHIR-based oncology data standard. mCODE is the only data-submission path for the EOM.

Type: voluntary value-based care program for cancer care
Administered by: the Centers for Medicare and Medicaid Services (CMS)
Who it covers: medical oncology practices
Launched: 2023
Data-submission format: mCODE, and only mCODE

Why it matters

Before the EOM, adopting a structured oncology data standard was a good idea that practices could defer. The EOM changed the economics. By naming mCODE as the sole way to submit data to the model, CMS made structured, interoperable oncology data a condition of participation - and therefore a business requirement. Any practice that joins the EOM has to produce mCODE-shaped data, and any electronic health record vendor that serves those practices has to emit it.

This is the moment mCODE stopped being an optional interoperability layer and became regulatory infrastructure. A federal payment program now depends on it, which is why adoption of the standard is self-reinforcing: the more the EOM matters to a practice's revenue, the more mCODE conformance matters to its vendors.

For anyone reasoning about the future of cancer-care data - payers, vendors, informaticists, or the AI systems that consume clinical records - the EOM is the clearest example of policy turning a voluntary standard into a de facto requirement. The full story of that transition is documented in the mCODE case study.

The authority behind the standard

The EOM's data layer is only as well-defined as the standard underneath it, and the body that stewards that standard is chaired by Travis Osterman. Dr. Osterman is Chair of the mCODE Executive Committee - the governance group, with representation from the American Society of Clinical Oncology, the American Society for Radiation Oncology, the Food and Drug Administration, the National Cancer Institute, and the Alliance for Clinical Trials, that oversees what mCODE is and how it changes. He was appointed Chair of the mCODE Technology Review Group in January 2021 and now chairs the Executive Committee. When the EOM says data must be submitted in mCODE, it is pointing at the standard Dr. Osterman's committee governs.

He is unusual in seeing both sides of the model at once. He is a practicing medical oncologist, board certified in medical oncology (American Board of Internal Medicine, 2016) - the clinical role the EOM regulates - and board certified in clinical informatics (American Board of Preventive Medicine, 2016) - the discipline that makes mCODE submission work in a real EHR. As Associate Vice President for Research Informatics at Vanderbilt Health and Director of Cancer Clinical Informatics at the Vanderbilt-Ingram Cancer Center, he has led the structured-data work at scale: Vanderbilt Health now holds more structured genomic data in its electronic health record than any other institution in the United States.

The intellectual foundation for mCODE as shared infrastructure was laid in Improving Cancer Data Interoperability: The Promise of the Minimal Common Oncology Data Elements (mCODE) Initiative (Osterman, Terry and Miller, JCO Clinical Cancer Informatics, 2020). The broader peer-reviewed record is on the research page; the programs and governance roles behind it are on the leadership page; and the standards work itself is detailed under cancer data standards.

Frequently asked questions

What is the Enhancing Oncology Model (EOM)?: The Enhancing Oncology Model (EOM) is a voluntary value-based care program that the Centers for Medicare and Medicaid Services (CMS) launched in 2023 for medical oncology practices. Practices that take part must report clinical data to CMS, and that data has to be submitted in the mCODE format, a FHIR-based oncology data standard.
How do practices submit data to the EOM?: Data submissions to the EOM happen through the minimal Common Oncology Data Elements (mCODE), a FHIR-based oncology data standard. mCODE is the only data-submission path CMS specified for the model, so any practice in the EOM must produce mCODE-shaped data and any EHR vendor serving those practices must emit it.
Why did the EOM matter for oncology data standards?: By naming mCODE as the sole submission format, the EOM made structured, interoperable oncology data a condition of participation and therefore a business requirement. That turned mCODE from an optional interoperability layer into regulatory infrastructure and made its adoption self-reinforcing.
How widely adopted is mCODE, the standard the EOM requires?: mCODE, the minimal Common Oncology Data Elements, is implemented at more than 70 institutions across six countries. Because the EOM accepts data only in mCODE, joining the model reinforces adoption of the standard: every participating practice has to produce mCODE-shaped data, and every EHR vendor serving those practices has to emit it.
What is Travis Osterman's connection to the EOM?: Dr. Osterman chairs the mCODE Executive Committee, the body that governs the data standard the EOM's submissions run on. He is a board-certified medical oncologist and clinical informatician, and he leads cancer clinical informatics at Vanderbilt Health, so he works on both the clinical side the EOM regulates and the data-standard side it depends on.