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The Ambulatory Specialty Model - Implications for Specialists, ACOs, and the Future of Medicare Payment Reform

12.04.25 | Presented by: David Pittman, Founder Pittman Policy Strategies and Sarah Habeeb Director, Government Programs, Baylor Scott & White Quality Alliance​​​


CMS finalized a new mandatory value-based payment model requiring downside risk for physicians treating heart failure and low back pain. With the Ambulatory Specialty Model starting in January 2027, join David Pittman and Sarah Habeeb to discuss what this means for physician practices, hospitals, and ACOs, where CMS is going with specialty-focused models, and how APMs and providers can thrive under new payment models. 



CMS has finalized a new mandatory value-based payment model—the Ambulatory Specialty Model (ASM)—which requires downside risk for physicians treating heart failure and low back pain.


During our recent webinar, David Pittman and Sarah Habeeb explored what ASM means for physician practices, hospitals, and ACOs; how CMS is evolving specialty-focused models; and what it will take for providers to succeed under these new payment structures.


They walked through ASM from both a regulatory and strategic lens, outlining what ACOs, medical groups, and hospitals should be preparing for as they begin navigating the model’s requirements. The points below capture only a small portion of the discussion—please review the slides and recording for full context.


“The burden associated with participation in ASM is required to achieve increased accountability on specialists managing beneficiaries with ASM’s targeted chronic conditions.” — CMS (PFS)


Key Regulatory Insights

  • ASM performance categories generally mirror MIPS, but are not identical.

  • ASM is not classified as an Advance APM.

  • Performance will be scored using an s-shaped logistic curve instead of the linear model used in MIPS.

  • Participation and scoring occur at the individual NPI level.

  • Clinicians in ACOs must dually report—fulfilling requirements for both ASM and their ACO programs.


Impact Analysis Insights

  • ASM payment adjustments are counted in MSSP expenditures.

  • Quality reporting both at ACO level and NPI level for ASM participants in an ACO

  • Medical groups must consider documented processes and procedures to meet three of five collaborative elements in CCA.

  • Specialists must assist patients with finding a PCP if necessary and collaborate with PCPs to ensure health related social need screenings are done.

  • Attributed specialist is accountable for transitions (emergency department visits and post-acute care costs included in the EBCM).


Thank you to our corporate sponsors who continue to help us fulfill our APM Connect Mission. This webinar was brought to you by:


Value Health Innovations: providing customized support to help hospitals, clinics and ACOs succeed in Alternative Payment Models (APMs). We identify improvement strategies, design initiatives, and can support or serve as your executive management team to drive implementation and results. Contact us at: admin@valuehealthinnovations.com Value Health Innovations | alternative payment models


scPharmaceuticals - Pioneering Care for the Heart and Kidney Connection; scPharmaceuticals is committed to revolutionizing cardiovascular and renal care through patient-centric approaches tailored to enhance outcomes, reduce burden, and increase quality of life. We are focused on advancing cardiorenal innovation through integrated treatments that address unmet patient needs. MannKind Corporation - Life more humann



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