The ASM Collaborative Care Arrangement: What Your Practice Needs to Know

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If your organization has physicians participating in the Ambulatory Specialty Model (ASM), the CCA is not optional. It is one of two required Improvement Activities under the ASM, and every eligible participant, whether a cardiologist treating heart failure patients or an orthopedic surgeon managing low back pain must complete it.

You don't have to figure this out alone. This is exactly why APM Connect exists. We hosted a live webinar on Collaborative Care Arrangements under ASM on June 18, featuring health care counsel Justin Brown (Bass Berry & Sims), Dr. Christian Pean (Duke & RevelAi Health), walking through how specialists are required to execute a Collaborative Care Agreement to avoid a negative 10 point penalty as part of the improvement activity component of ASM.

Here is what it means, what it requires, and how to get it done.

What Is a Collaborative Care Arrangement?

A Collaborative Care Arrangement is a formal, executed agreement between an ASM participant (the specialist) and at least one primary care practice. The purpose is straightforward: to ensure that the specialist and primary care physician are actually communicating and coordinating on the care of shared ASM beneficiaries not operating in separate silos.

This requirement is codified in the CY 2026 Physician Fee Schedule Final Rule at 42 CFR § 512.735(c)(2)(ii). CMS designed it to push specialists toward the kind of active care coordination that reduces avoidable hospitalizations and closes gaps in chronic disease management for patients with heart failure or low back pain.

What Must the CCA Include?

The Final Rule specifies that each CCA must include at least three of the following five collaborative elements:

• Data sharing:  structured exchange of clinical information between the specialist and the primary care practice

• Co-management:  shared decision-making on care plans for attributed ASM beneficiaries

• Transitions in care planning:  coordinated handoffs when patients move between care settings

• Closed-loop connections:  documented follow-through on referrals, test results, or recommendations sent between the two practices

• Care coordination integration:  alignment of care management workflows between the specialist and primary care (42 CFR § 512.735(c)(2)(ii)(A)–(E))

  
  

  You do not need all five. You need at least three, and the agreement must be executed in writing before you attest. 

How Is It Reported?

The CCA is reported as part of Improvement Activity IA-2, submitted at the TIN level with a 90-day reporting period. Because submission is at the TIN level, some practice managers have worried that a large organization would need to roll out CCA workflows across all of its providers. That is not the case.

From the Final Rule: "The ASM participant must enter into at least one CCA with a primary care practice... regarding their shared ASM beneficiaries." (42 CFR § 512.735(c)(2)(ii))

The attestation covers what the ASM participant is doing for their specific ASM beneficiaries not what every provider in the TIN is doing for their entire patient panel. A health system with two cardiologists in a 2,000-provider TIN is attesting that those two cardiologists have an active CCA in place. The other providers are unaffected.

What You Should Do Now

The model launches January 1, 2027. The 90-day reporting period means the CCA must be in place before the performance year ends. Here is a practical checklist:

• Identify your ASM participants using the preliminary list at data.cms.gov

• Identify the primary care practices that share the most patients with each ASM participant, these are your natural CCA partners

• Decide which three (or more) of the five collaborative elements fit your existing workflows

• Draft and execute a written CCA agreement with at least one primary care practice per ASM participant

• Retain the executed CCA for attestation, no additional data submission is required beyond the attestation itself

The Bottom Line

The Collaborative Care Arrangement is one of the more operationally concrete requirements in the ASM. It requires an agreement with a primary care partner, not just a checkbox. But it is also manageable if you start early, identify the right primary care partners, and keep the scope focused on the ASM participant and their attributed beneficiaries.

The specialists who will struggle are those who wait until late 2027 to begin. The ones who will be ready are those who start building those primary care relationships now.

Sources & References

CY 2026 Physician Fee Schedule Final Rule, Federal Register, November 5, 2025 (42 CFR § 512.735(c)(2)(ii)(A)–(E))

ASM Q&A Follow-Up Document, ASM Reality Check Webinar (May 2026)

CMS Innovation Center — Ambulatory Specialty Model: cms.gov/priorities/innovation/innovation-models/asm