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The Ambulatory Specialty Model (ASM) is a Centers for Medicare & Medicaid Services (CMS) Innovation Center model that begins on January 1, 2027 and will include select anesthesiologists and pain medicine physicians. ASA encourages CMS to amend ASM to ensure that anesthesiologists and pain medicine physicians have the opportunity to effectively participate in the model and receive positive payment adjustments. ASA is working on multiple fronts to protect our members from the model’s unreasonable and burdensome requirements.
Check to see if you are on the 2027 ASM preliminary participant list.
ASM begins with payment adjustments that range from -9% to +9% in the first year and climb to -12/+12% in the model’s last year. These payment adjustments are substantial and do not allow enough time for anesthesiologists and their groups to adjust to the ASM reporting requirements. Even ASM participants who have experience with MIPS will have to adjust to the mandatory quality measures, lack of special status designations, and mandated individual reporting. Anesthesiologists and their groups need time to adjust workflows and develop new reporting capabilities before facing significant negative payment adjustments.
The model’s overall redistribution percentage of 85%, which deviates from the typical 100%, also increases the likelihood that many model participants will receive sizable negative payment adjustments.
CMS has not planned to provide historic benchmark data in advance for anesthesiologists and their groups to assess their past performance on the designated quality and cost measures. Despite CMS’ stated emphasis on transparency, the program’s structure ensures participants will not have access to necessary data to assess their performance in the model and adjust workflows accordingly.
Additionally, ASM does not incorporate appropriate eligibility thresholds like those found in the MIPS program. MIPS only requires clinicians who exceed all three low‑volume criteria (generate more than $90,000 in Medicare Part B charges, see more than 200 Medicare patients, and perform more than 200 covered services) to participate. However, ASM applies a far lower bar—any physician with a qualifying specialty who bills under the Medicare Physician Fee Schedule, practices in a selected geographic area, and is attributed just 20 episodes related to the episode‑based cost measure is automatically swept into mandatory participation.
ASM does not account for special statuses. MIPS recognizes special statuses for non‑patient‑facing, hospital‑based, small practice, and ASC‑based clinicians. Those special statuses appropriately exempt most anesthesiologists from reporting the PI category. These special statuses reduce reporting burden, recognize anesthesiologist and pain medicine physician workflows, and are crucial for many anesthesia practices to receive fair assessments in MIPS. A substantial number of ASM participants qualify for MIPS special statuses, meaning that they may not have any experience reporting PI and it may not be appropriate for them to report the PI category. For the majority of groups that only have a small subset of their members included as participants of ASM, navigating between ASM and MIPS policy differences is sure to add an extra layer of complexity and administrative burden.
Individual‑level assessment in ASM breaks from the vast majority of physicians who report MIPS as a group. By requiring individual participation, CMS has created operational complexity for groups who may have one or two ASM participants and hundreds of other physicians who may or may not choose to repost Traditional MIPS. The increased burden of reporting ASM requirements for one or two anesthesiologists in a group is significant.
As currently designed, the rigid and mandatory quality measure set for the ASM low back pain cohort provides substantial administrative burden. The policy requires participants to report measures that many have never reported and fail to reflect clinical workflows. This policy deviates from MIPS, where it is understood that physicians should choose to report the most relevant and practical measure. One of the required ASM measures—Functional Status Change for Patients with Low Back Impairments (MIPS #220)—is notoriously difficult to report and no anesthesiologist or pain medicine physician reported MIPS #220 in 2023 (the last year of available data).
It should also be noted that ASM is based upon a low back pain episode-based cost measure that has historically failed to attribute anesthesiologists or pain medicine physicians to a significant number of cases. Early CMS and Acumen field testing showed most attribution of that cost measure was focused on other specialties such as chiropractic, physical therapy, and physical medicine and rehabilitation.
ASA has highlighted our concerns with ASM by:
Reach out to ASA Department on Quality and Regulatory Affairs with questions or comments: qra@asahq.org
This page is curated by the ASA Department of Quality and Regulatory Affairs and was last updated April 2026.
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You do not have to make a payment at this time, but you can reach out to your practice/group leader to find out when they plan to pay your dues. Email or call the ASA Support team for assistance: (630) 912-2552 or info@asahq.org.
