• The proposed rule would implement changes through a unified framework known as the Quality Payment Program, which includes two paths, the Merit-Based Incentive Payment System (MIPS) or the Alternative Payment Model (APM), with proposed quality measures for each. Aside from a handful of preapproved primary care medical homes and other ACO-like models, most physician specialists—including emergency physicians—will begin to report quality and resource use data in 2017 under MIPS, while some groups will consider developing APMs over the next few years.
• ACEP has established an APM Task Force to help develop arrangements that will allow emergency physicians to participate in these new payment systems, although the practice of emergency medicine does not easily fit into any of the existing or proposed models. ACEP submitted formal comments on June 27, describing its myriad concerns with this very complex and burdensome draft regulation.
• ACEP expects the final rule to be published along with (or as part of) the annual Medicare Physician Fee Schedule for 2017, which is effective Jan. 1.
Tomar is ACEP’s federal affairs director.