- General
- Eligibility
- Data Reporting
Additional ASM technincal FAqs (PDF) are also available.
General
How did CMS develop ASM?
In developing ASM, CMS consulted with multiple stakeholders, including medical providers, health systems, specialty associations, and thought leaders in the healthcare field. ASM is further informed by responses to the Request for Information in the CY 2025 Physician Fee Schedule rule. ASM's regulations are informed by public comments received on proposals made through the Physician Fee Schedule’s notices of proposed rulemaking.
What is ASM testing?
ASM will test whether holding select physician specialists accountable for the quality and cost of care associated with the longitudinal management of specific chronic conditions, heart failure and low back pain, can reduce Medicare expenditures while preserving or enhancing quality of care for Original Medicare beneficiaries. Clinical decisions made by specialists in ambulatory settings can meaningfully influence disease progression as well as downstream utilization and spending. ASM’s design, in its goal to reduce Medicare costs while preserving or enhancing the quality of care, will aim to achieve the following: (1) improvement in the management of chronic disease and slow disease progression through more effective risk assessment; (2) increased active collaboration between specialists and primary care providers; and (3) reduced avoidable hospitalizations and low-value procedures (that is, procedures that provide little clinical benefit or the risk of harm outweighs its potential benefit).
What resources are available to ASM participants to guide them through ASM?
CMS is committed to supporting ASM participants throughout their participation 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. ASM 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.
For additional information, ASM updates, and invitations to future webcasts, please subscribe to the ASM listserv.
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 medical 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 medical provider attrition and selection bias.
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.
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)). ASM participants are identified as individual physicians using a unique Taxpayer Identification Number (TIN) and National Provider Identifier (NPI) combination. 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 2025 data to determine final eligibility for the 2027 performance year.
CMS determines whether an ASM participant continues 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 that they do not need to meet certain ASM for that ASM performance year and will instead be subject to MIPS reporting requirements if applicable.
The ASM Participants dataset is available on data.cms.gov. The dataset indicates the ASM performance year(s) for which each ASM participant must meet ASM requirements.
Data Reporting
What is the deadline for data reporting and how will ASM participants report data?
ASM participants must report the required data and attestations for the quality, improvement activities, and Promoting Interoperability ASM performance categories by March 31 following the end of an ASM performance year. For example, for the 2027 ASM performance year, ASM participants must report data by March 31, 2028.
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.
Does ASM reporting replace MIPS reporting for ASM participants?
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 requirements and uses different scoring and payment adjustment methodologies than MIPS.
ASM participants are exempt from MIPS reporting requirements during the ASM performance years in which they are required to meet model obligations, with certain exceptions. As a result, ASM participants who are exempt from MIPS reporting requirements cannot participate in MIPS or receive a MIPS payment adjustment for those years.
The Innovation Center is working with the Quality Payment Program to adjust MIPS eligibility determinations because of required participation in ASM.
Please note that physicians who are eligible for MIPS in CY 2026 should continue to report to MIPS for CY 2026, even if they appear as a preliminary ASM participant for the 2027 performance year. ASM does not begin until January 1, 2027.
Payment
How does ASM’s payment methodology work?
ASM’s payment methodology converts each ASM participant’s final score into an ASM payment adjustment factor that CMS will use to adjust an ASM participant’s Medicare Part B covered professional service payments during the corresponding ASM payment year. An ASM participant (TIN/NPI) will receive a final score for an ASM performance year based on their performance in the four ASM performance categories: quality, cost, improvement activities, and Promoting Interoperability. CMS compares final scores within each ASM cohort to calculate an ASM participant’s ASM payment adjustment factor applied during the corresponding ASM payment year. For example, the final score earned for the 2027 ASM performance year will determine the ASM payment adjustment factor applied to payments for Medicare Part B covered professional services during the 2029 ASM payment year. The ASM payment adjustment factor will range from -9 percent to +9 percent in the first two ASM payments years (2028 and 2029) and will increase in later ASM payment years. The application of ASM payment adjustments will be similar to the application of MIPS payment adjustments.