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Summer is here, and the heat is on: barbeques, beaches, and the 2026 CMS Physician Fee Schedule Proposed Rule. Throughout 1,803 pages, CMS is going after the total cost of care in the MIPS and APM tracks of the Quality Payment Program (QPP).
These proposed updates and the creation of a surprise new (and mandatory!) Alternate Payment Model (APM), share themes that you need to recognize to ensure that your Value-Based Care strategy has long-term viability.
1. Two-sided risk will come for everybody, and it will be mandatory.
The biggest news to come out of this Proposed Rule is the creation of a new and mandatory two-sided risk model named the “Ambulatory Specialty Model” or “ASM”. As we’ve predicted, CMS has taken another step toward mandatory, two-sided risk models. Required participation eliminates the selection bias that can corrupt the data from voluntary models and furthers CMS’s goal of having all Medicare patients in accountable care relationships by 2030.