The 2026 Governance Mandate: Operationalizing ASCO-COA’s New Culture of Safety

Photo by Bill Branson

By mid-2026, the ASCO Certified Program will incorporate the 2025 updates to the Oncology Medical Home (OMH) standards, developed jointly by American Society of Clinical Oncology (ASCO) and the Community Oncology Alliance (COA). While organizations might approach these revisions as another accreditation cycle requirement, doing so would fundamentally misread their significance.

The updated standards are not a refinement of “it’s just our culture” theory. They represent a governance mandate: oncology practice leadership is now expected to oversee a Culture of Safety that is operational, multidisciplinary and explicitly non-punitive particularly in how errors, near misses and system failures are surfaced and managed. In an environment of escalating malpractice exposure, payer scrutiny and AI-mediated care workflows, this shift is best understood not as compliance enhancement, but as a strategic defense against liability accumulation.

From “It’s Just our Culture” to Governed Safety Systems

For the past decade, just our culture has been widely adopted in healthcare as a philosophical framework emphasizing fairness, learning and avoidance of blame. In practice, however, it has often remained abstract: embedded in policy language, referenced in training, but weakly enforced in daily operations.

The updated OMH standards move decisively past philosophy. They operationalize safety as a managed system, requiring oncology organizations to demonstrate:

• Non-punitive error reporting mechanisms that staff actually use

• Formal multidisciplinary team (“MDT”) structures for reviewing safety events

• Leadership accountability for closing feedback loops, not merely documenting them

  
  

This evolution matters because oncology care delivery has become structurally more complex. Care is increasingly longitudinal, distributed across settings and dependent on handoffs among clinicians, navigators, pharmacists, informaticists and now AI-supported workflows. In this environment, safety failures are rarely the result of a single actor. They are system failures and regulators are signaling that leadership must treat them as such.

Leadership Oversight Is No Longer Indirect

Historically, some administrators have treated safety culture as an operational concern delegated to clinical leadership. The revised ASCO-COA standards narrow that distance. They implicitly assert that safety culture is a governance responsibility, not merely a management aspiration.

This has three concrete implications for practice leaders and administrators:

1. Visibility replaces reassurance

   Leaders can no longer rely on high-level quality dashboards that mask weak reporting cultures. Low incident counts are no longer prima facie evidence of safety; they may indicate underreporting driven by fear or futility.

2. Error reporting becomes a leading indicator of risk

   Non-punitive reporting is reframed from “nice to have” to essential infrastructure. Organizations that cannot demonstrate psychologically safe reporting environments will struggle to defend themselves in the event of adverse outcomes.

3. MDT management becomes a liability control

   The standards elevate multidisciplinary review from collegial best practice to risk mitigation mechanism. When safety events are reviewed through an MDT lens, organizations create contemporaneous evidence that decisions were reasoned, collective and system-aware: an increasingly important defense posture.

   
   

Why This Matters Now: Liability, Not Idealism

The timing of this mandate is not accidental. Oncology organizations are facing rising professional liability premiums, more aggressive plaintiff strategies and expanding theories of institutional negligence. At the same time, care models are absorbing new sources of error risk, including automation bias, documentation inaccuracies and delayed escalation in patient support workflows.

In this context, the ASCO-COA standards function as a regulatory proxy for legal expectations. They define what a “reasonable” oncology organization should have in place to identify, surface and respond to harm.

Organizations that treat the Culture of Safety as a compliance artifact risk two outcomes:

• Operational fragility, as errors remain hidden until they escalate

• Defensive weakness, as the absence of robust reporting and MDT review is reframed as negligence rather than oversight

  
  

Conversely, organizations that operationalize these standards can demonstrate that adverse events occurred despite, not because of reasonable, governed systems.

The Strategic Reframe: Safety as an Asset

The most forward-leaning oncology leadership will recognize that the updated OMH standards offer something rare: a chance to convert safety infrastructure into strategic protection.

A governed Culture of Safety:

• Reduces surprise by surfacing weak signals early

• Improves care continuity by strengthening cross-disciplinary coordination

• Creates defensible records of organizational intent and response

• Aligns clinical quality, workforce trust and enterprise risk management

  
  

This is particularly critical as AI-supported processes become embedded in patient navigation, triage and follow-up: domains where errors are often subtle, cumulative and difficult to attribute to a single decision.

2026 as a Governance Test

By mid-2026, the question for oncology leadership will be whether they can credibly assert that safety is designed, monitored and enforced as a system, not assumed as a value.

The updated ASCO-COA OMH standards make that expectation explicit. Organizations that respond with minimal compliance will satisfy auditors but remain exposed. Those that treat the Culture of Safety as a practice leadership-level mandate will be better positioned to withstand the operational and legal pressures defining the next phase of oncology care delivery.

In 2026, safety is no longer a cultural aspiration. It is governance in action.

Reference

American Society of Clinical Oncology. Updated Oncology Medical Home standards published July 21, 2025 in JCO Oncology Practice.

Header image was released by the National Cancer Institute, an agency part of the National Institutes of Health