Healthmonix Advisor

The frantic pace, high-stakes decisions, and unpredictable patient flow of the emergency department make it a unique and challenging environment in healthcare. For years, the Merit-based Incentive Payment System (MIPS) program has presented a formidable obstacle for emergency physicians, and now the Cost category will have a measure just for emergency medicine in your 2024 feedback. This part of MIPS, which assesses the total cost of care for patients, can feel disconnected from the realities of emergency medicine, where the primary goal is rapid stabilization and appropriate disposition, not cost control. 

On July 10, 2025, CMS released the CY 2026 Medicare Physician Fee Schedule (PFS) Proposed Rule. While CMS characterized 2026 as a “stabilization year,” the Proposed Rule brings several notable updates to the Merit-Based Incentive Payment System (MIPS), particularly around MIPS Value Pathways (MVPs), the Cost performance category, and registry participation.  

These changes are crucial for providers aiming to protect their reimbursement, streamline reporting, and improve performance. 

As CMS continues to evolve value-based care, the Ambulatory Specialty Model (ASM) in the 2026 Physician Fee Schedule (PFS) Proposed Rule represents a landmark opportunity for specialists who have historically been excluded from broader accountable care models like MSSP and ACO REACH. 

As you report your MIPS data, it can feel like a lot of work with little ROI for the last two years. But wait. Sometimes we need to step back and evaluate the bigger picture. While we often focus on "getting the job done", there are changes in the healthcare economy that are occurring that are strategic.