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New Proposed Mandatory Model: Ambulatory Specialty Model (ASM) Synopsis



In the 2026 Medicare Physician Fee Schedule Proposed Rule, CMS introduced the Ambulatory Specialty Model (ASM)—a new mandatory payment model targeting specialists who treat heart failure and low back pain.


ASM represents a major shift in accountability, emphasizing individual clinician performance and directly linking quality and cost to future Part B payment adjustments.


Ambulatory Specialty Model (ASM)


Key Strategic Ambulatory Specialty Model (ASM) Components


  • Performance at the clinician level – No aggregation or system-level shielding

  • Scoring heavily weighted in quality and cost

  • Peer-relative final scores – Payment adjustments will depend on how an individual clinician performs compared to their peers


ASM is designed to increase competition among specialists, reduce the advantage of large consolidated health systems, and directly reward high-performing individual clinicians.



What Is Ambulatory Specialty Model (ASM)?


CMS aims to incentivize specialists to improve outcomes and reduce costs for heart failure and low back pain through future Part B payment adjustments.


Key points from the proposal:


  • Specialists would have 9% to 12% of their Part B reimbursements at risk

  • Adjustments are based on a composite score across:

    • Quality

    • Cost

    • Improvement Activities

    • Promoting Interoperability

  • Payment adjustments follow the clinician if they move to a different TIN

  • Participation and performance are at the individual NPI level

 


Key Features of Ambulatory Specialty Model (ASM)

  • Performance period: 2027–2031

  • Payment adjustments: 2029–2033

  • NPI-level data reporting only

  • CMS will select clinicians for mandatory participation based on geography

 

Participation Eligibility


Targeted Physician Cohorts:

  • Heart Failure: Cardiologists

  • Low Back Pain: Anesthesiology, pain management, neurosurgery, orthopedic surgery, physical medicine & rehabilitation


Requirements:

  • Must bill under the Medicare Physician Fee Schedule

  • Must have ≥20 attributed episodes per year for targeted conditions

  • Must be located in CMS-mandated geographic areas

 


Scoring & Payment Adjustments


ASM scoring categories mirror MIPS, but the methodology is different:

  • Quality: 50% of composite score

  • Cost: 50% of composite score

  • Improvement Activities & Promoting Interoperability: Neutral or negative adjustment only


Key differences from MIPS:

  • No minimum performance threshold for payment adjustment

  • Final score is peer-relative – clinicians are compared to other specialists in their cohort

  • Designed to encourage competition among individual specialists

 


Be Prepared


  • Preliminary eligibility lists expected late 2025

  • Final clinician selection will be announced July 2026

  • Payment adjustments begin in 2029


APM Connect will continue to monitor ASM developments and provide updates on participation requirements, reporting expectations, and peer insights as the program evolves.


Together, we can prepare for ASM and transform specialty care one step at a time.



Join TEAM Connect today.

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