The ASM Participant List - Eligibility Explained

ASM Participant Eligibility Criteria

CMS determines ASM participant eligibility using the following criteria. A clinician must meet all four to be subject to mandatory participation in a given performance year.

1. Billing StatusThe clinician bills claims under the Medicare Physician Fee Schedule

2. Specialty Type The clinician is identified by TIN/NPI as a selected specialty type

3. Episode Volume Threshold The clinician meets the episode-based cost measure (EBCM) volume threshold for an ASM-targeted chronic condition

4. Geographic Location The clinician is located in a mandatory geographic area selected by CMS. These locations are posted on the CMS website.

Specialty Types Included in ASM

ASM participation is limited to clinicians whose Medicare Part B claims reflect one of the following specialty types on the plurality of claims:

Heart Failure Specialty Type

• Cardiology

Low Back Pain Specialty Types

• Anesthesiology

• Interventional Pain Management

• Neurosurgery

• Orthopedic Surgery

• Pain Management

• Physical Medicine and Rehabilitation

Episode-Based Cost Measure (EBCM) Volume Thresholds

CMS uses EBCM episode volume to determine eligibility, based on attribution methodology specified under MIPS and a two-year lookback period.

Heart Failure

• Clinician is a cardiologist

• 20 or more heart failure EBCM episodes

• Episodes attributed during the calendar year two years prior to the ASM performance year

Low Back Pain

• Clinician practices in an eligible low back pain specialty

• 20 or more low back pain EBCM episodes

• Episodes attributed during the calendar year two years prior to the ASM performance year

Change in TIN During an ASM Performance Year

If an ASM participant changes TINs during an ASM performance year:

• The clinician must notify CMS within 30 days, using a CMS-specified process

• For that performance year:

  • The clinician is not subject to ASM requirements

  • The clinician is no longer eligible for ASM waivers

  • MIPS reporting obligations apply, if applicable

Key Takeaway

Under § 512.710, ASM participation is mandatory, data-driven, and multi-year in nature. Clinicians may remain ASM participants for the duration of the model while moving in and out of ASM performance requirements depending on annual eligibility, episode volume, specialty, geography, and organizational changes such as TIN reassignment.

Understanding how these elements align across performance, reporting, and payment years is essential for compliance and planning under ASM.