- What is ambulatory specialty care?
Ambulatory specialty care refers to specialized medical services delivered in outpatient settings rather than performed in hospitals. While the CMS Innovation Center is currently testing hospital-based alternative payment models such as the Transforming Episode Accountability Model (TEAM), ASM would focus on outpatient specialty care of chronic conditions.
- How did CMS develop ASM?
ASM responds to the Make America Healthy Again agenda which calls for lowering rates and impacts of chronic disease. In accordance with the Innovation Center strategic pillar of promoting evidence-based prevention, ASM would hold participants accountable for screening and risk identification in addition to patient experience and health outcomes. Specialists would be rewarded for effective upstream disease management, adhering to clinical guidelines for care, and coordinating with other providers involved in the management of their patients’ care. In developing this model, CMS consulted with several stakeholders, including providers, health systems, specialty associations, and thought leaders in the health care field. ASM is further informed by lessons learned from a Request for Information in the CY 2025 Physician Fee Schedule rule. Final policies will be informed by public comments received during the rulemaking process.
- Where would ASM be tested?
CMS would implement ASM in regions throughout the country, including Core-Based Statistical Areas (CBSAs) and Metropolitan Divisions, geographic regions defined by the federal government for the purpose of collecting statistics. The CMS Innovation Center seeks performance data from a wide range of markets that represent demographic variation across the nation.
- Why would participation in ASM be mandatory for selected specialists?
Mandatory models can improve the generalizability of model findings and capture a wider variety of 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 provider attrition and selection bias, which, in turn, burdens taxpayers instead of providing them with savings.
- Will specialists be given time to transition to ASM?
CMS intends to release an initial list of ASM participants by the end of the 2025 calendar year (CY) and plans to finalize that list during CY 2026 to give specialists time to prepare for ASM requirements that will go into effect in CY 2027.
- Can providers participate in ASM and other Innovation Center models simultaneously?
ASM would allow participants to remain in other CMS Innovation Center Models and accountable care organizations (ACOs), including the Medicare Shared Savings Program.
- How is ASM different than MIPS?
ASM is a mandatory Innovation Center alternative payment model. While ASM leverages the performance measurement framework from MIPS Value Pathways (MVPs), ASM participants would be exempted from MIPS requirements for applicable ASM performance years. While many of the measures, scoring policies, and application of payment adjustments would be familiar to ASM participants that were previous MIPS eligible clinicians, ASM has different participant requirements and uses a different payment adjustment methodology than MIPS.
Page Last Modified:
07/14/2025 04:09 PM