If you’re a cardiologist or a specialist treating low back pain, you’ve likely spent years building a rhythm around MIPS reporting. Selecting measures, tracking your score, adjusting your approach each performance year. The Ambulatory Specialty Model changes that rhythm for a defined group of clinicians starting in 2027.
ASM is not simply a renamed version of MIPS. It borrows pieces of the MIPS Value Pathways framework, but it changes who has to participate, how much of your revenue is at risk, and how your performance gets measured against your peers.
This guide walks through exactly what changes when a clinician moves from MIPS into ASM, what stays familiar, and where Patient360 fits into that transition.
Participation Goes From Optional to Mandatory
Under MIPS, participation depends on eligibility thresholds, and clinicians who fall below certain volume or billing levels can be excluded or can choose to report voluntarily. There’s flexibility built into the program, and many practices have spent years managing their MIPS/MVP Registry Reporting around that flexibility.
ASM removes that flexibility for a specific group. If a clinician’s specialty, billing pattern, and location meet the eligibility criteria within a CMS-selected region, participation happens automatically. There’s no opt-in decision to make and no opt-out available once a clinician is identified.
This is one of the starkest differences between the two programs. A clinician who has never reported under MIPS voluntarily could still be pulled directly into ASM if their claims history matches the criteria. There’s also no practice-level shield. CMS identifies participants at the individual clinician level, using TIN and NPI, so one specialist in a group practice could be mandated into ASM while a colleague in the same practice is not, depending on each clinician’s specialty designation and episode volume.
That individual-level selection is a meaningful operational shift. Practices accustomed to managing MIPS reporting as a group now need to track eligibility separately for each clinician who treats heart failure or low back pain in any meaningful volume.
Your Payment Risk Gets Broader
Under MIPS, a payment adjustment applies to MIPS-covered services. It’s a meaningful amount, but it’s scoped to a defined set of billing.
Under ASM, the scope of risk expands considerably. A payment adjustment applies to all of a participant’s Medicare Part B claims, not only the services tied to heart failure or low back pain. A specialist with strong performance on the measured condition but poor documentation elsewhere could still see a negative adjustment ripple across their entire Part B billing.
Adjustments under ASM involve up to 9% downside risk and apply two years after the relevant performance year, meaning 2027 performance directly impacts 2029 payments. It is critical to understand that this model is not budget neutral like MIPS. Instead, CMS uses an incentive pool: funds withheld from lower performers are collected, CMS retains a portion to guarantee Medicare savings, and the remainder is redistributed to fund the positive adjustments for higher performers across their entire Part B billing.
Additionally, clinicians who treat more complex patient populations, or who practice in smaller settings, qualify for positive scoring adjustments that add flat points directly to their final score before the payment multiplier is calculated. That’s a nuance worth understanding early, since those bonus points can meaningfully change how a raw score translates into an actual financial outcome.
Not sure how this broader risk exposure compares to what you’re used to under MIPS? Contact us today and our team can walk through the difference using your own claims data.
How You’re Compared to Other Clinicians Changes
MIPS compares your score against a national pool of MIPS-eligible clinicians across specialties. ASM narrows that comparison considerably. Your performance is measured against other clinicians treating the same condition within the same geographic region, whether that’s heart failure or low back pain.
This regional, condition-specific benchmarking means your ASM score reflects how you manage a defined patient population relative to your direct peers, not the broader MIPS population. CMS addresses how this cohort comparison works in its ASM frequently asked questions.
For specialists used to MIPS scoring, this narrower comparison group can feel like a more direct spotlight on day-to-day clinical management, rather than a broader administrative exercise.
What Stays the Same
Despite the differences, ASM isn’t a completely new framework. Both programs measure performance across four connected categories: Quality, Cost, Improvement Activities, and Promoting Interoperability. CMS’s own Quality Payment Program overview outlines how these categories function under MIPS, and ASM builds directly on that same architecture.
ASM also continues to rely on the MIPS Value Pathways structure CMS has been developing for several years, so clinicians who have already reported through an MVP will recognize the underlying scoring logic even as the participant pool and stakes change.
Reporting Requirements Change Too
Under MIPS, clinicians typically choose from a wide menu of quality measures, sometimes hundreds, depending on specialty. Practices often work with a QCDR to access measure sets tailored to their specialty when the standard MIPS measure inventory doesn’t fit well.
ASM narrows that menu considerably. Measures are built around the specific condition, heart failure or low back pain, and applied at the individual clinician level rather than the practice or group level. CMS assigns clinicians to a region based on where the majority of their episodes occurred, so a clinician splitting time across locations won’t be able to choose their reporting region.
This narrower measure set can feel like a relief after years of sorting through hundreds of MIPS quality measures to find the right fit, but it also means less room to shape your score around measures where your practice naturally performs well. Under MIPS, a specialist with a weaker showing on one measure could often offset it by reporting strongly elsewhere in a broader set. Under ASM, the measurement scope is tighter, so consistent performance on the specific condition matters more directly.
Who Is Actually Affected
Not every MIPS-reporting specialist moves to ASM. CMS applies specific eligibility criteria within selected regions:
- At least 20 attributed episodes of heart failure or low back pain, based on the MIPS episode-based cost measures
- A specialty designation that matches
How Patient360 Helps You Transition
the included categories, currently general cardiology for heart failure, and anesthesiology, pain management, interventional pain management, neurosurgery, orthopedic surgery, or physical medicine and rehabilitation for low back pain
- Billing under the Medicare Physician Fee Schedule within a CMS-selected Core-Based Statistical Area or Metropolitan Division
CMS released a preliminary participant list in early 2026 based on 2024 data, with a final list expected by summer/fall 2026 based on 2025 data. Eligibility is reassessed every year for the life of the model, which means a clinician excluded in one performance year could still be added in a later year if their claims pattern shifts, and a clinician included initially could be removed if their volume or specialty designation changes.
That annual reassessment is a meaningful departure from how many clinicians think about MIPS eligibility, which tends to be more stable year over year. Under ASM, a change in referral patterns, a shift in patient mix, or a change in how services are billed could move a clinician in or out of the participant pool without much warning.
Curious whether your claims history and specialty would place you in the ASM participant pool? Contact us and our team can review your data with you.
Preparing for the Transition
Specialists who expect to move from MIPS into ASM shouldn’t wait for the final participant list to start preparing. The two-year gap between a performance year and its corresponding payment adjustment can feel like breathing room, but documentation habits and care coordination structures take time to build correctly, and retroactive fixes are far harder than getting the workflow right from the start.
A few steps make the shift considerably smoother:
- Review historical claims data against the 20-episode threshold before assuming you’re excluded
- Confirm whether your practice location falls within a CMS-selected region
- Formalize a documented relationship with at least one primary care provider, since ASM requires coordination that MIPS does not
- Audit your current MIPS documentation habits against the episode-based cost measures ASM scoring relies on
- Build reporting workflows now rather than after the model launches in 2027
If questions come up along the way, Patient360’s Frequently Asked Questions page covers many of the common transition questions we hear from clients moving between reporting programs.
How Patient360 Helps You Transition
As one of the original 16 CMS Qualified Registries, in continuous operation since 2009, Patient360 has helped specialty practices navigate reporting program changes for a long time. Our services span MIPS/MVP Registry Reporting, QCDR reporting, ACO reporting, and eCQM registry reporting, giving practices a single, consistent partner regardless of which program they’re moving into.
The shift from MIPS to ASM changes more than terminology. Participation becomes mandatory instead of optional, financial risk expands from covered services to your entire Part B billing, and your performance gets compared against a narrower, condition-specific peer group. What doesn’t change is the underlying discipline of accurate documentation, timely data submission, and understanding exactly where you stand before CMS finalizes participation.
If your practice is trying to determine what ASM will mean for your reporting obligations, reach out to Patient360, and let us help you compare your current MIPS performance against what ASM will expect starting in 2027.
