- General
- Eligibility
- Quality Performance Category
- Cost Performance Category
- Improvement Activities Performance Category
- Promoting Interoperability Performance Category
- Data Reporting
- Payment
- Model Overlap
General
- What is ambulatory specialty care?
Ambulatory specialty care refers to specialized medical services delivered in outpatient settings rather than performed in hospitals. While the CMS Innovation Center is currently testing hospital-based alternative payment models such as the Transforming Episode Accountability Model (TEAM), ASM will focus on outpatient specialty care of chronic conditions.
- How did CMS develop ASM?
ASM responds to the Make America Healthy Again agenda which calls for lowering rates and impacts of chronic disease. In accordance with the Innovation Center strategic pillar of promoting evidence-based prevention, ASM will hold participants accountable for screening and risk identification in addition to patient experience and health outcomes. Specialists will be rewarded for effective upstream disease management, adhering to clinical guidelines for care, and coordinating with other providers involved in the management of their patients’ care. In developing this model, CMS consulted with several stakeholders, including providers, health systems, specialty associations, and thought leaders in the health care field. ASM is further informed by lessons learned from a Request for Information in the CY 2025 Physician Fee Schedule rule. ASM's final provisions are informed by comments received on the CY 2026 Physician Fee Schedule notice of proposed rulemaking.
- How is ASM different than the Merit-based Incentive Payment System (MIPS)?
ASM is a mandatory Innovation Center alternative payment model. While ASM leverages the performance measurement framework from MIPS Value Pathways (MVPs), ASM participants will be exempted from MIPS requirements for applicable ASM performance years. While many of the measures and application of payment adjustments will be familiar to ASM participants that were previous MIPS eligible clinicians, ASM has different participant requirements and uses different scoring and payment adjustment methodologies than MIPS.
What must ASM participants do to meet the ASM participation requirements?
ASM participants are required to submit data on the required measures and activities for the quality, improvement activities, and Promoting Interoperability ASM performance categories by the data submission deadline. For additional information on ASM data reporting requirements, please refer to the Data Reporting section of the FAQs.In addition to submitting performance data, ASM participants must comply with all model requirements outlined in ASM regulations. Please refer to 42 CFR part 512, subpart G for all ASM regulations.
- What resources are available to participants to guide them through ASM?
CMS is committed to supporting ASM participants throughout their journey in ASM. To help guide ASM participants, key resources are available on the ASM website. CMS will continue to expand these resources before model launch in 2027. Participants should review ASM’s regulations (42 CFR part 512, subpart G) and the CY 2026 Physician Fee Schedule Final Rule in the Federal Register for comprehensive information on model requirements.
Eligibility
- Why will participation in ASM be mandatory for selected specialists?
Mandatory models can improve the generalizability of model findings and capture a wider variety of providers from across the country, including many who have not participated in value-based payment models. Mandatory models also address participation challenges inherent in voluntary models, namely provider attrition and selection bias, which, in turn, burdens taxpayers instead of providing them with savings.
- How does CMS identify ASM participants?
CMS identifies ASM participants using the ASM participant eligibility criteria in accordance with ASM's regulations (42 CFR part 512, § 512.710(b)). Individual physicians that meet the following criteria are identified as ASM participants:- Bill claims under the Medicare Physician Fee Schedule
- Have a selected specialty type related to an ASM targeted chronic condition
- Are attributed to 20 or more episodes from the episode-based cost measure (EBCM) related to their specialty type and ASM targeted chronic condition
Practice in one of the selected mandatory geographic areas
CMS uses data from the calendar year two years before a given ASM performance year to evaluate these criteria. For example, CMS will use data from 2025 to determine final eligibility for the 2027 performance year.
Which specialty types are included in ASM?
For the heart failure cohort, physicians with a specialty type of cardiology are considered for participation. For the low back pain cohort, physicians with the following specialty types are considered for participation: anesthesiology, interventional pain management, neurosurgery, orthopedic surgery, pain management, or physical medicine and rehabilitation. For the purposes of ASM, CMS determines specialty type based on the specialty code on the majority of a clinician’s Medicare Part B claims used to evaluate the ASM participant eligibility criteria for a given performance year. At this time, non-physician providers are not eligible to participate in ASM.
Are physicians in Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) included in the ASM participant list?
Physicians who exclusively provide services billed under the Rural Health Clinics (RHCs) or Federally Qualified Health Centers (FQHCs) payment systems will not be selected to participate in ASM. However, physicians who practice in RHCs or FQHCs and separately provide and bill for services under the Medicare Physician Fee Schedule (PFS) and meet the ASM participant eligibility criteria will be required to participate in ASM as CMS determines ASM eligibility using PFS claims.
Where will ASM be tested?
CMS will implement ASM in regions throughout the country, including Core-Based Statistical Areas (CBSAs) and Metropolitan Divisions, geographic regions defined by the federal government for the purpose of collecting statistics. The CMS Innovation Center seeks performance data from a wide range of markets that represent demographic variation across the nation. Selected ASM mandatory geographic areas are available on the ASM website.
Is there a list of ASM participants available?
The ASM Participants dataset is now available. The dataset indicates the ASM performance year(s) in which each ASM participant must meet ASM requirements.
How do I confirm if I am or a physician at our practice is an ASM participant?
Please visit the ASM Participants dataset to check if a physician is listed as an ASM participant.
Will physicians be given time to transition to ASM?
For the 2027 performance year, CMS has released a preliminary list of ASM participants (view the ASM Participants dataset). If CMS identifies a change in your service location, specialty type, or the type or volume of services that warrants a participant’s exclusion for the 2027 performance year, CMS plans to notify participants by late summer 2026. CMS also plans to release additional ASM resources throughout CY 2026 to help ASM participants prepare for model launch on January 1, 2027.
If a physician is listed as an ASM participant for the upcoming performance year, will they continue as an ASM participant for all remaining performance years of the model?
CMS will determine whether ASM participants continue to meet the ASM participant eligibility criteria on an annual basis. If an ASM participant no longer meets the ASM participant eligibility criteria for a given performance year, CMS will notify them. In this instance, the ASM participant will not need to meet ASM’s model requirements for that performance year and will instead be subject to MIPS reporting requirements if applicable.
How does CMS determine if an ASM participant is part of a small practice?
When CMS identifies ASM participants for the upcoming performance year based on ASM participant eligibility criteria, CMS will also determine each participant’s practice size. For the purposes of ASM, a small practice is a practice (TIN) consisting of 15 or fewer clinicians.
Quality Performance Category
What quality measures must ASM participants report?
ASM includes two sets of quality measures, one for heart failure ASM participants and one for low back pain ASM participants. Each measure set includes five quality measures. Please find the list of measures below for each ASM participant cohort. Unless otherwise noted, the quality measures will use existing MIPS specifications. These specifications can be found on the Quality Payment Program website.
| Measure | Collection Type(s) |
|---|---|
Heart Failure | |
| Risk-Standardized Acute Unplanned Cardiovascular-Related Admission Rates for Patients with HF (MIPS Q492) (modified specifications) | Claims |
| HF: Beta-Blocker Therapy for LVSD (MIPS Q008) | eCQM MIPS CQM |
| HF: ACE Inhibitor or ARB or ARNI Therapy for LSVD (MIPS Q0005) | eCQM MIPS CQM |
| Controlling High Blood Pressure (MIPS Q236) | eCQM MIPS CQM |
| Functional Status Assessments for Heart Failure (MIPS Q377) | eCQM |
Low Back Pain | |
| Use of High-Risk Medications in Older Adults (MIPS Q238) | eCQM MIPS CQM |
| Preventive Care and Screening: Screening for Depression and Follow-Up Plan (MIPS Q134) | eCQM MIPS CQM |
| Preventive Care and Screening: BMI Screening and Follow-Up Plan (MIPS Q128) | eCQM MIPS CQM |
| Functional Status Change for Patients with Low Back Impairments (MIPS Q220) | MIPS CQM |
| Excess Utilization Measure- To Be Determined in CY 27 Rulemaking | Claims |
Cost Performance Category
Which cost measures are ASM participants scored on?
ASM participants are scored using the same episode-based cost measures (EBCMs) that are used to determine ASM participant eligibility. These cost measures are also used in MIPS.
- Heart failure ASM participants are scored on the heart failure EBCM
- Low back pain ASM participants are scored on the low back pain EBCM.
These measures are calculated by CMS using claims data, so ASM participants are not required to report any data.
Detailed information, including Measure Information Forms, are available on the MIPS website.
Improvement Activities Performance Category
What improvement activities must an ASM participant complete during a performance year?
An ASM participant must complete Improvement Activities 1 (IA-1): Connecting to Primary Care and Ensuring Completion of Health-Related Social Needs Screening and Improvement Activity 2 (IA-2): Establishing Communication and Collaboration Expectations with Primary Care using Collaborative Care Arrangements.
Specifications for the two required improvement activities can be found in ASM’s regulations (42 CFR part 512, § 512.735(c)) and further discussed in most recent Physician Fee Schedule Final Rule in the Federal Register.
Promoting Interoperability Performance Category
What measures and attestations are required in ASM's Promoting Interoperability performance category?
ASM’s Promoting Interoperability requirements largely mirror those used in MIPS. Specific requirements for ASM’s Promoting Interoperability performance category are included in ASM’s regulations (42 CFR part 512, § 512.740) and are further discussed in most recent Physician Fee Schedule Final Rule in the Federal Register.
Data Reporting
What is the data reporting deadline?
ASM participants must report the required data and attestations for the quality, improvement activities, and Promoting Interoperability performance categories by March 31 following the end of a performance year. For example, for the 2027 performance year, ASM participants must report data by March 31, 2028.
How will participants report data?
CMS will release further guidance on data reporting. CMS plans to use the Quality Payment Program (QPP) portal for ASM participants to report required data, which is the same portal used for MIPS data submissions.
Do ASM participants need to report performance category data at the individual or group level?
Only ASM participants in small practices are allowed to report quality data at the group (TIN) level. All other ASM participants must report quality data at the individual (TIN/NPI) level. All ASM participants must report improvement activities and Promoting Interoperability data at the group (TIN) level. ASM Participants are not required to report any cost data but will be scored at the individual (TIN/NPI) level.
Payment
How does ASM's payment methodology work?
ASM’s payment methodology converts each ASM participant’s final score into a payment adjustment that CMS will use to adjust an ASM participant’s Part B covered services payments during the corresponding ASM payment year. For example, the final score earned for the 2027 performance year will determine the payment adjustment applied to payments for 2029 Part B covered professional service claims. The application of ASM payment adjustments will be similar to the application of MIPS payment adjustments. Each ASM participant (TIN/NPI) receives a final score for a performance year based on their performance in the four performance categories: quality, cost, improvement activities, and Promoting Interoperability.
CMS compares final scores within each cohort to calculate an ASM participant’s payment adjustment that will be applied to an ASM participant’s future Part B payment for covered professional services during the corresponding payment year. This payment adjustment will range from -9 percent to +9 percent in the first two payments years (2028 and 2029) and will increase in later payment years.
Will each ASM participant receive an individual final score and payment adjustment?
Yes. Each ASM participant (TIN/NPI) receives their own payment adjustment that will be applied to their individual Part B payments for covered professional services.
Model Overlap
Can physicians and their billing organizations participate in ASM and other Innovation Center models simultaneously?
ASM will allow ASM participants to remain in other CMS Innovation Center Models and accountable care organizations (ACOs), including the Medicare Shared Savings Program.
Can an ASM participant participate in MIPS while participating in ASM?
ASM participants are exempt from MIPS reporting requirements during the ASM performance years in which they are required to meet model obligations. As a result, they cannot participate in MIPS or receive a MIPS payment adjustment for those performance/payment years.