I know what you may be thinking…where are the Medicare regs? It’s supposed to be reg season, but there seems to be a major reg drought! Don’t worry, the regs are coming.
The major one we are waiting for is the Medicare physician fee schedule, which will make changes to the Quality Payment Program (QPP)—the main quality reporting program for physicians in Medicare. The QPP includes two tracks—last week’s blog focused on the first track, the Merit-based Incentive Payment System (MIPS), and this week, I’m talking about the other track—alternative payment models (APMs).
Under the QPP, physicians who participate in certain APMs, such as accountable care organization (ACO) and bundled payment models that include downside financial risk, can receive a 5 percent payment bonus through 2024. If physicians aren’t in these APMs, they most likely have to meet the MIPS requirements (with some exceptions). Unfortunately, as an emergency physician, you have no opportunities to directly participate in an APM.
To fill this gap in available APMs, ACEP developed a Medicare-focused APM called the Acute Unscheduled Care Model (AUCM). Structured as a bundled payment model, the AUCM (pronounced “Awesome”) would improve quality and reduce costs by allowing emergency physicians to accept some financial risk for the decisions they make around discharges for certain episodes of acute unscheduled care.
ACEP submitted the AUCM to a federal advisory committee called the PTAC that makes recommendations to the Secretary of the Department of Health and Human Services (HHS) on Medicare APM proposals. The PTAC recommended the AUCM to the HHS Secretary for full implementation! However, as of today, we are still waiting on the HHS Secretary to respond to the PTAC’s recommendation. (Click here to read the AUCM proposal and here to see PTAC’s full report to the Secretary.)
As we enter into our tenth month of waiting for the HHS Secretary to weigh in, we have heard from many of you that you don’t want to wait and are interested now in participating in an APM like AUCM. You’ve likely seen the writing on the wall that many payers (private payers and Medicaid) are moving away from fee-for-service (FFS) toward more value-based contracts, and an APM like AUCM could be a solution that you could proactively present to them.
While we are hopeful that the HHS Secretary will eventually call on CMS to implement AUCM in Medicare, we are kicking off a strategic initiative to promote participation in emergency medicine-focused APMs for other payers.
More details on this initiative are forthcoming, but expect to see more information and resources in the next few months that will help you engage with Medicaid offices and private payers on APMs, decide whether or not to participate in an APM, and learn how to be successful in an APM.
Until next week, this is Jeffrey saying, enjoy reading regs with your eggs!