Article
What is locked in
The CMS Innovation Center’s Ambulatory Specialty Model (ASM) runs five performance years, from Jan. 1, 2027 through Dec. 31, 2031. It targets Original Medicare patients with heart failure or low back pain. Participation is set at the individual clinician level, by TIN and NPI combination: cardiologists in the heart failure group, and anesthesiologists, pain and interventional pain physicians, neurosurgeons, orthopedic surgeons and physiatrists in the low back pain group. Clinicians qualify by historical episode volume (at least 20 attributed episodes) and by practicing in one of the selected geographic areas, roughly a quarter of all CBSAs and metro divisions. CMS has already posted the final 2027 participant list on data.cms.gov.
Scores across quality, cost, improvement activities and interoperability drive two-sided adjustments to future Part B professional payments. The maximum is 9% up or down in 2029 and 2030, rising to 12% by 2033. According to Becker’s reporting on the model’s terms, total bonuses are capped at 85% of total penalties, so the pool is designed to be net-negative.
The pushback
On Oct. 27, 2026, the AHA and a coalition of other groups wrote to CMMI asking it to postpone the launch or, failing that, remove downside risk for the first year. They also asked for performance thresholds before the start date, timely data and a single help desk, and permission to report quality at the practice level. The same day, the Center for Healthcare Quality and Payment Reform published an analysis estimating that more than 5,500 specialists are in the model across 235 areas. About one-third of those areas are entirely rural, and in 19% of them a single cardiologist is assigned. CMS issued its CY 2027 Physician Fee Schedule final rule on Nov. 4, 2026, finalizing changes to ASM while retaining its Jan. 1, 2027 start. Leaders should review the final requirements before launch.
What to model and do now
- Match your roster to the list. Pull every employed and affiliated TIN/NPI from the CMS participant dataset, and identify the cardiology and spine service lines exposed.
- Size the downside. Apply 9% and 12% negative scenarios to each participant’s Medicare Part B professional revenue. Then test how a penalty would flow through compensation plans and practice subsidies.
- Find thin-coverage risk. Where one or two specialists cover a rural market, a penalty or a departure could reduce access and push referrals elsewhere. Build retention and recruitment contingencies into those plans.
- Stand up the care requirements. The model calls for collaborative care arrangements with primary care, health-related social needs screening, shared transition plans and certified EHR data exchange. Assign owners and complete contracting before January.
- Baseline the cost measures. Episode-based cost scores reflect downstream spending, including imaging, procedures and post-acute use. Work with finance and quality to establish 2027 baselines.
Sources
- AHA, others advocate on mandatory payment model for specialists (AHA News, Oct 29, 2026)
- CMS specialty model could harm rural patients: Report (Becker’s Hospital Review, Oct 27, 2026)
- Ambulatory Specialty Model (CMS Innovation Center, Oct 13, 2026)
- Ambulatory Specialty Model Final Rule (Epstein Becker Green, Dec 9, 2025)

