$200 Million, 6,637 Clinicians, Zero Choice

$200 million in penalties. 6,637 clinicians. No opt-out. By Christian Pean MD, MS

Access Full Article $200 Million, 6,637 Clinicians, Zero Choice

CMS just published the participant list database for the Ambulatory Specialty Model — the first mandatory two-sided risk model aimed squarely at cardiologists and spine/pain specialists at the provider level.

I pulled the list, cross-referenced every NPI against the Medicare Part B Public Use File, and built an interactive financial exposure dashboard.

→ Look up your NPI at TechyPolicy.com — the interactive tool shows your individual Part B allowed amounts, penalty exposure at each year’s rate (9% → 12%), cohort assignment, small practice designation, and organizational context. If you manage a group, the organization scorecard aggregates all ASM participants within your entity.

What I found:

The average provider faces ~$30,000 in annual penalty exposure at the Year 1 rate of 9%. 

Nearly 1,000 clinicians face over $50,000. 

Over 200 face six-figure penalties. And at the top end — providers whose Part B billings exceed $4M — individual penalties approach half a million dollars in Year 1 alone.

By Performance Year 2031, the rate climbs to 12%. At that point, over 400 providers exceed $100K in exposure, and some organizations are staring at $1.5–1.9M in aggregate risk across their employed specialists.

This isn't MIPS. There's no hardship exemption. No opt-out pathway. And the performance threshold is peer-relative, which means clinicians who performed well under MIPS may still land on the wrong side of the curve.

A few observations:

Heart Failure cohort providers carry significantly higher per-provider exposure (approximately $40K avg) than Low Back Pain (approximately $24K avg) — largely driven by higher beneficiary volumes and risk scores in cardiology.

The geographic concentration is striking. Texas, Florida, and California account for nearly half of total penalty exposure.

And the organizational view may be the most important lens. Health Organizations with 15-40 ASM participants don't always realize they have $500K–$1.5M in collective downside sitting inside their employed specialty groups.

Looking at the distribution of the organizations selected--this is not a model that will be on the radar for your typical IDN or academic medical center. These are largely private practices, and individual physicians who were selected. In fact, 1300 of the organizations have just a single NPI in the model.

I built the full analysis — including a multi-year penalty calculator and organization-level risk scorecards — by combining CMS public data, Python scripting, and Claude AI. The entire workflow from data acquisition to interactive visualization was AI-assisted and preliminarily validated with help from Darren Michael, PhD CC SC.

If you're a cardiologist, spine surgeon, pain management specialist, or health system leader — you can check whether you or your organization is on the participant list at techypolicy.com and check out my article on the model today. This model is coming January 2027. The time to understand your exposure is now. And if you're looking for help automating the required measures, reach out!