8 analyses and summaries · 5 working guides
Value-Based Care Policy Analysis & Insights
CMS rules, read by people who have had to operate under them.
Policy analysis, specialty summaries, and practical guides: the reference material we wish had existed when we were working through these programs ourselves.
Latest analysisACOs & MSSP · Rulemaking
The CY2027 Proposed Rule for MSSP ACOs: What Changes, What It Pays, and Where We Stand
Quality reporting relief, a new collection type decision, the first serious fix to the benchmark ratchet in a decade, and a 32% E/M payment modifier gated on participant-list status. What CMS proposed and where VBCA stands.
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Published Jul 15, 2026, updated Sep 23, 2026 · 10 min read
2026 MIPS reporting is due March 31, 2027.
Start with the guide, then check your measures against the 2026 benchmarks.
By program
8 analyses and 5 guides, sorted by the program they cover
Filter by the program you report under: MIPS, a Medicare ACO, or the Ambulatory Specialty Model (ASM). Rulemaking collects the proposed and final rules behind all three.
Showing 13 of 13, newest analysis first
- · 10 min readAnalysisACOs & MSSP · RulemakingThe CY2027 Proposed Rule for MSSP ACOs: What Changes, What It Pays, and Where We StandQuality reporting relief, a new collection type decision, the first serious fix to the benchmark ratchet in a decade, and a 32% E/M payment modifier gated on participant-list status. What CMS proposed and where VBCA stands.
- · 8 min readAnalysisMIPS · ACOs & MSSP · ASM · RulemakingCY2027 Physician Fee Schedule Proposed Rule: Summary and AnalysisThe proposed conversion factors, the specialty impact table, the Ambulatory Specialty Model's first-year provisions, the proposed end of traditional MIPS, and the ACO package. Comments were due September 14, 2026.
- · 4 min readPerspectiveMIPSBusiness Viability Is Healthcare Access: Why VBCA ExistsWhy VBCA exists: what our founders learned running value-based programs inside large physician enterprises, and why the compliance tax threatens independent practices.
- · 3 min readAnalysisASMCMS Releases Preliminary Ambulatory Specialty Model (ASM) Participant List6,637 clinicians identified for mandatory ASM participation in 2027. What the preliminary list means, key statistics, and what to do next.
- · 5 min readSpecialty summaryASMAmbulatory Specialty Model (ASM) for Spine & Pain Specialists: What Low Back Pain Clinicians Need to KnowA practical summary of the Ambulatory Specialty Model (ASM) for spine and pain specialists: participation, scoring, quality measures, and the data available now to prepare.
- · 4 min readSpecialty summaryMIPS · ASMAmbulatory Specialty Model (ASM) for Cardiologists: What Heart Failure Specialists Need to KnowA practical summary of the Ambulatory Specialty Model (ASM) for cardiologists: participation, scoring, quality measures, and the data available now to prepare.
- · 11 min readAnalysisMIPS · ASMThe Ambulatory Specialty Model ExplainedHow the Ambulatory Specialty Model scores cardiologists and spine and pain specialists, what it pays from 2029 to 2033, and what to have in place by January 1, 2027.
- · 3 min readAnalysisASM · RulemakingCMS Is Building Both the Test and the Tools to Pass ItHow the Ambulatory Specialty Model, TEAM, ACCESS, and LEAD fit together: CMS pairs mandatory episode risk for specialists with new payment for the care it rewards.
- Working guideGuideMIPS2026 MIPS Reporting: Requirements, Deadlines, and What the Score Is WorthWho must report, what each of the four categories requires, how scoring turns into dollars, and every deadline through the March 31, 2027 submission window. Maintained through the performance year.
- Working guideGuideMIPSMIPS Reporting Deadlines: The Complete 2026 TimelineEvery date in the 2026 MIPS cycle in one table: the Oct 3 Improvement Activities cutoff, Nov 30 MVP registration, Dec 31 exception applications, and the Jan 4 to Mar 31, 2027 submission window.
- Working guideGuideMIPSThe MIPS Penalty: What It Costs, Who Gets It, and How to Avoid ItThe score-to-adjustment math, what the full -9% costs at each revenue level, who actually gets penalized, and the seven moves that still prevent it for 2026 reporting.
- Working guideGuideMIPSMIPS Eligibility in 2026: Do You Have to Report?The low-volume threshold, the two determination periods, opt-in versus voluntary reporting, exclusions, and how to check your status at every practice where you bill.
- Working guideGuideASMASM Preparation: What You Can Do NowPractical guide to using the preparation window before ASM launches in January 2027. Checklists covering cost position, quality measures, primary care relationships, and reporting infrastructure.
In the works
- Cost Is a Clinical Problem
- The MVP Transition Timeline: What Practices Need to Know
Analysis explains what CMS changed. The guide and the measure tools turn it into this year's reporting.
For the 2026 performance year
The 2026 MIPS guide, and the measure data it points to
The guide covers who must report, what each category requires, and every date through the submission window. The tools answer the measure-level questions it raises.
Guide
2026 MIPS Reporting: Requirements, Deadlines, and What the Score Is Worth
Who must report, what each of the four categories requires, how scoring turns into dollars, and every deadline through the March 31, 2027 submission window. Maintained through the performance year.
- 1622026 MIPS quality measuresEvery measure in the 2026 set, each with its specification.
- 105Measures with 2026 benchmarksDecile thresholds and topped-out status by collection type, in one table.
- 48Specialty measure setsThe measures available to your specialty, with their benchmarks.
- 5,556ASM participant lookupMedicare's final list of specialists for the Ambulatory Specialty Model, across 46 states.
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