The CMS Ambulatory Specialty Model (ASM) is a mandatory CMS Innovation Center model that adjusts Medicare Part B payments for selected specialists who care for patients with heart failure or low back pain, based on performance from January 1, 2027. Integral Healthcare Solutions (IHS) drafts the roster check, reporting calendar, data workflow and primary care arrangement templates a specialty group needs before the first performance year.
IHS is a consulting firm, not a law firm. CMS decides who participates; you and your counsel decide the response.
Last updated: November 6, 2026
What is the CMS Ambulatory Specialty Model?
ASM is a test under section 1115A of the Social Security Act, set out in 42 CFR part 512, subpart G. CMS says “ASM is a mandatory model with five performance years that run from January 1, 2027, through December 31, 2031” (CMS, ASM model page, last modified November 5, 2026). The regulation sets a seven-year test period, January 1, 2027, to December 31, 2033, that covers every performance year and every payment year (42 CFR 512.705). CMS’s FAQ says the 2027 final score sets the adjustment applied in 2029.
On November 4, 2026, CMS announced the CY 2027 Physician Fee Schedule final rule (CMS-1848-F), which finalizes ASM changes (CMS press release). The eCFR text IHS opened, built November 4, 2026, does not yet show them, so this page takes each change from CMS’s ASM fact sheet on the final rule and marks it “CY 2027 final rule.”
| Part of the final score | How it counts (eCFR text; CMS may assign other quality and cost weights) |
|---|---|
| Quality | 50 percent; participants submit measure data, CMS calculates claims-based measures |
| Cost | 50 percent; CMS calculates it from claims, and a measure needs 20 cases unless CMS specifies otherwise |
| Improvement activities | Deduction: none at a category score of 100 percent, 10 points at 50 percent, 20 points at zero |
| Promoting Interoperability | Deduction of up to 10 points (2027 transition: CY 2027 final rule) |
| Added points | Complex patient 0 to 10 (risk indicator at or above the cohort median); small practice 10 (solo 15); rural 5 (CY 2027 final rule); each only with a final score above zero |
Final scores run from zero to 100, and CMS compares them within each cohort (42 CFR 512.745, 512.750).
Who needs it and what triggers it
A clinician is an ASM participant when CMS finds all four of these (42 CFR 512.710(b)): the clinician bills under the Medicare Physician Fee Schedule; is identified by TIN and NPI as a selected specialty type; meets the episode volume threshold; and is located in a mandatory geographic area. Cardiology is the heart failure cohort; the low back pain cohort is anesthesiology, interventional pain management, neurosurgery, orthopedic surgery, pain management and physical medicine and rehabilitation, judged by the specialty code on the plurality of the clinician’s Part B claims.
The threshold is 20 or more episodes of the cohort’s condition under the MIPS episode-based cost measure, counted two calendar years before the performance year. On geography, after excluding some areas, the regulation says CMS “selects approximately 40 percent of CBSAs and metropolitan divisions from each stratum,” while CMS’s model page says “roughly one-quarter” of core-based statistical areas (CBSAs) and metropolitan divisions. Use CMS’s list of mandatory geographic areas, not either figure.
CMS built the 2027 list from 2024 data (preliminary) and 2025 data (final); IHS counted CMS’s ASM Participants dataset on November 6, 2026: 5,556 clinicians, 2,215 heart failure and 3,341 low back pain. From the 2028 performance year CMS rechecks earlier participants and can add new ones.
- Act when a clinician appears in the dataset: CMS’s onboarding checklist says one who did not receive CMS’s notification email should register for the ASM Participant Portal with the NPI.
- Act when a clinician leaves the selecting TIN or, in the heart failure cohort, changes specialty to one of five designations in CMS’s fact sheet (CY 2027 final rule exceptions), or when January 1, 2027 nears with no owner for quality data.
How IHS helps
Thomas G. Goddard, JD, PhD, IHS founder and former URAC Chief Operating Officer and General Counsel, leads the work. IHS runs three practice lines, Accreditation Consulting, Compliance Services and Program Development; this is Program Development.
The process
- Gap assessment and roster map: a TIN and NPI check against the CMS dataset, and an owner for each performance category.
- Drafting: a verification procedure, measure-ownership matrix, data-flow and EHR checklist, improvement activity evidence index, a collaborative care arrangement template for your counsel and clinicians to approve, and a calendar to March 31.
- Readiness review: IHS lists what the finished package lacks, an IHS method, not a CMS step.
What you supply
Your TIN and NPI roster, EHR details, data owners, primary care partners, a finance exposure estimate and counsel’s review of any arrangement that moves money.
The real limit
IHS does not submit data to CMS, contact CMS or model payment results as a financial adviser. Your clinicians, finance team and counsel own the measure choices, exposure estimate and signed arrangements.
What to have ready
- A TIN and NPI roster with specialty and location, checked against the dataset and CMS’s list of mandatory areas.
- ASM Participant Portal registration for each listed clinician, and current Medicare enrollment, which CMS uses under the CY 2027 final rule to find TIN and specialty changes.
- A quality data source for each cohort measure: numerator and denominator data for at least one non-claims measure that meets the completeness rule, and data on at least 75 percent of eligible patients regardless of payer for each required non-claims measure (512.720, 512.725). Heart failure: MIPS Q492 (claims-based), Q008, Q005, Q236, Q377. Low back pain, CY 2027 final rule: Q238, Q134, Q128, Q182 and a claims-based lumbar spine MRI measure.
- A review of the episodes attributed to each clinician, since CMS calculates cost from claims (512.730).
- Improvement activity evidence: for IA-1, processes for primary care access, reporting back to the primary care provider and social needs screening follow-up; for IA-2, at least one executed collaborative care arrangement covering at least three of five listed elements (512.735).
- Your Promoting Interoperability filing: for 2027, a 100 percent category score requires CEHRT use, the CMS EHR Certification ID and the dates of a continuous 180-day period in 2027, submitted at the TIN level (CMS fact sheet). Measures and attestations apply from 2028.
- A reporting calendar: data and attestations are due March 31 after each performance year, or a later date CMS specifies; CMS plans to use the Quality Payment Program portal.
- A records plan: six years from the last payment determination or from the completion of any audit, evaluation, inspection or investigation, whichever is later; longer if CMS notifies you of a special need at least 30 days before the normal disposition date, and six more years after a termination, dispute or allegation of fraud or similar fault is finally resolved (512.135).
The free introductory call is where IHS walks through this list with you.
How it compares
- ASM: mandatory; CMS selects individual specialists by TIN and NPI.
- MIPS: an existing program. ASM participants are exempt from MIPS reporting in the ASM years they must meet model obligations, with certain exceptions.
- CMS ACCESS Model: CMS calls it voluntary, and participation starts with an application; see the IHS ACCESS Model readiness page.
What it costs
Three costs apply, and only one is an IHS fee. First, the cost of the model itself: the CMS pages IHS opened state no participation fee, so none is quoted here, but the payment adjustment changes Part B payments. CMS’s model page says payment adjustments “range from -9% to +9% in the first two ASM performance years, increasing to -12% to +12% by the final ASM performance year,” and its FAQ gives -9 percent to +9 percent for the first two payment years, 2029 and 2030. A participant who does not meet the quality submission requirement gets a final score of zero, unless an extreme and uncontrollable circumstance exempts the participant, and a zero score carries an adjustment factor equal to the negative of the ASM risk level, the maximum downside CMS sets (42 CFR 512.745, 512.750 and 512.780).
Second, IHS scopes each engagement after a free introductory call. Scope moves with the clinicians, TINs, EHR systems and primary care partners on your roster, and how far reporting is from CMS requirements.
Third, your own staff and counsel time.
What this is not
- It is not legal advice or a forecast. IHS gives no opinion on 42 CFR part 512, on whether a clinician is a participant, or on an arrangement that moves money, and guarantees no score or payment.
- IHS does not submit data to CMS or contact CMS.
- An ASM collaborative care arrangement is a written agreement between a specialist and a primary care practice, a different subject from the Collaborative Care Model that IHS covers on its own page.
Frequently asked questions
What is the Ambulatory Specialty Model?
ASM is a mandatory CMS Innovation Center model with five performance years, January 1, 2027, through December 31, 2031. It adjusts Medicare Part B payments for selected heart failure and low back pain specialists under a two-sided risk arrangement.
How do I find out whether my clinicians are ASM participants?
Look each clinician up in the ASM Participants dataset on data.cms.gov, which CMS says shows the performance years for which each participant must meet ASM requirements.
Can a clinician opt out of ASM?
The CMS pages and regulation text IHS opened describe mandatory participation and no participant-initiated opt-out. A clinician who does not meet the criteria in a given year is not subject to the model that year, and the CY 2027 final rule revises the TIN-change exception and adds one for heart failure participants who change specialty to one of five listed designations; an excepted participant remains a participant for the test period (CMS fact sheet).
Can a nurse practitioner or physician assistant participate?
Not at this time. CMS’s FAQ says “At this time, non-physician providers are not eligible to participate in ASM.”
How does ASM relate to MIPS?
CMS says 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 participants are exempt from MIPS reporting requirements during the ASM performance years in which they are required to meet model obligations, with certain exceptions.
What must we report, and when?
Quality data, improvement activity attestations and Promoting Interoperability information are due March 31 after each performance year, or a later date CMS specifies; for 2027 the default is March 31, 2028.
What did the CY 2027 final rule change for ASM?
Changes in CMS’s fact sheet include a revised TIN-change exception and a new heart failure specialty-change exception, a lumbar spine MRI measure and MIPS Q182 in place of Q220 for low back pain, a 2027 Promoting Interoperability transition, a 5-point rural scoring adjustment and revised collaborative care arrangement rules.
What is a collaborative care arrangement under ASM?
Under 42 CFR 512.771 as opened, it must be in writing, signed by both parties, show an effective date and be exclusively between the ASM participant and a primary care practice that shares at least one established patient who is an ASM beneficiary. IA-2 needs at least one executed arrangement covering at least three of five elements. The CY 2027 final rule lets one or more participants under the same TIN enter a single arrangement with a primary care practice if each is named as a party and the practice and at least one of those participants share an ASM beneficiary.