ASA Encourages CMS to Amend and Improve the Ambulatory Specialty Model

Earlier this week, ASA met with the Centers for Medicare & Medicaid Services (CMS) to advocate for changes to the Ambulatory Specialty Model (ASM). ASA emphasized that the model poses significant challenges for anesthesiologists and focused on providing constructive recommendations that lessen these impacts. Without these changes, over 1,000 anesthesiologists and pain medicine physicians will be required to participate in ASM next year and face significant barriers to succeeding and earning a positive payment adjustment in the model. 

ASA urged CMS to:
• Provide a longer on-ramp for participation by reducing negative penalties and providing participants with historic performance benchmarks on ASM measures. 
• Extend special statuses within the Merit-based Incentive Payment System (MIPS) to ASM participants. These special statuses recognize anesthesiologist and pain medicine physician workflows, ensuring that the Promoting Interoperability performance category is not used to undermine a physician’s final score. 
• Expand the required ASM measure set by including more anesthesiologist-related measures and allowing physicians to choose which measures to report.

Physician leaders from ASA’s Committee on Pain Management and ASA Center for Anesthesia and Perioperative Economics, Quality, and Advocacy staff participated in the meeting. ASA will continue to engage with CMS staff on potential improvements to ASM. 

ASM is a mandatory Innovation Center model that was developed using the Merit-Based Incentive Payment System (MIPS) Value Pathways (MVP) framework. The model, which will run from 2027 to 2031, targets specialists who frequently treat low back pain or heart failure in selected geographic areas. The participant list includes anesthesiologists and pain medicine physicians within the low back pain cohort. ASM participants will be assessed individually and subject to performance-based payment adjustments ranging from -9% to +9% in the first year. 

ASA provided comments on the ASM model last year. 

Learn more about ASM and how ASA is advocating for changes to the Model that reflect the realities of anesthesia care.

Please contact the ASA Department of Quality and Regulatory Affairs at qra@asahq.org with any questions.