Prepare for CMS Ambulatory Specialty Model (ASM) reporting with Patient360. Our ASM reporting solution helps eligible specialty practices manage required quality data, track performance, benchmark results and prepare for CMS submission ahead of the 2027 performance year.
Learn how we can help
ASM
Starting at
per provider
Includes:
- Meet annual minimum reporting threshold
- P360 portal access for secure uploads
- Invites to P360’s Lunch & Learn webinars
- Avoid negative payment adjustment
- Opportunity to earn positive payment adjustment
- Frictionless data submission via CMS submission API*
- Data submission all ASM categories
- Quality
- Promoting Interoperability (PI)
- Improvement Activities
- Real-time score calculator
- Manual entry or template data import
- QRDA I/III and CSV data import available
- Opportunity to impact outcomes and performance
- Expert analytic tools
- Real-time data analysis
- Comparison w/benchmark scoring analytics – national data comparison within TIN
* Subject to 2027 CMS Final Rule
Importance of ASM Reporting
The Ambulatory Specialty Model (ASM) is a new mandatory program from the CMS Innovation Center. CMS considers the ASM valuable because it incentivizes “upstream” management. Instead of rewarding specialists for the volume of procedures or visits, the model rewards them for keeping a patient’s condition stable and out of the hospital. By focusing on Heart Failure and Low Back Pain, two conditions that account for billions in annual Medicare spending, CMS is targeting the areas where better specialty management can have the most immediate impact on preventive care and keeping patient costs low.
By partnering with Patient360 and utilizing Patient360 Reporting Solution, providers gain access to tools and expertise that ensure complete, compliant, and timely data submission to CMS. The solution also helps providers stay aligned with ASM updates, benchmark comparisons, and performance thresholds, all of which are critical for success in today’s value based care environment.
How Does the Patient360 Solution Work?
It is designed to make the complex process of ASM submissions as seamless and efficient as possible. Here’s how it works:
Provider Eligibility & Enrollment
First, review the CMS Innovation Center ASM Model website participant list to determine if any of your providers are required to participate in the program. If you do have required participant (s), you may enroll them through Patient360’s secure portal. Our experienced team guides you through onboarding, ensuring your organization is correctly configured for the current ASM performance period.
Data Collection & Import
You can enter performance data manually, import it using templates, QRDA I or III files, or via EHR integration.
Real-Time Scoring & Benchmarking
Once data is uploaded, the system calculates real-time performance scores across all ASM categories (where applicable.) Providers can compare their scores against national benchmarks within their Tax Identification Number
Expert Review & Optimization
Our analytics team reviews your data, providing actionable feedback to help boost your ASM score. We ensure submissions are CMS compliant and optimized for maximum incentive
Secure Submission to CMS
At the end of the reporting period, P360 securely submits your validated data to CMS (pending CMS Final Rule). This helps avoid penalties and ensures timely, accurate reporting with no technical surprises.
Feedback and Performance Monitoring
Before, during, and after submission, providers receive feedback reports. Patient360 helps interpret the results, offering insights and strategic planning.
Get Started Today
Your time matters, so does your performance. With Patient360, Ambulatory Specialty Mode (ASM) becomes streamlined, accurate, and impactful. Upload data securely, track real-time progress, and meet CMS requirements without hassle. Join providers nationwide who trust our tools to reduce risk and enhance incentive opportunities. It starts with one click.
The Ambulatory Specialty Model is a mandatory CMS Innovation Center model for specialists treating heart failure or low back pain. Participation is determined and scored at the individual clinician (TIN/NPI) level, and performance is measured against other specialists treating the same condition rather than the full MIPS pool. The base score is 50% Quality and 50% Cost. Improvement Activities and Promoting Interoperability carry no upside and apply only as negative scoring adjustments.
The model runs five performance years, 2027 through 2031. The first performance year begins January 1, 2027, with payment adjustments applied two years later (PY2027 affects payment year 2029). The preliminary participant list was released in early 2026 using 2024 claims; the final list for PY2027 is expected in July 2026 using 2025 claims. Only clinicians on the preliminary list are reassessed for the final list, so that list can shrink but not grow.
Clinicians who meet all four criteria:
- Specialty on the plurality of Medicare Part B claims: Cardiology (Heart Failure cohort); Anesthesiology, Interventional Pain Management, Neurosurgery, Orthopedic Surgery, Pain Management, or Physical Medicine and Rehabilitation (Low Back Pain cohort)
- Bills claims under the Medicare Physician Fee Schedule
- Meets the episode-based cost measure threshold of 20 attributed episodes (COST_HF_1 or COST_LBP_1)
- Practices in a CMS-selected mandatory geographic area
Note that 20 patients does not equal 20 episodes. EBCM attribution rules require active management of the condition. Specialty designation flows from PECOS, and CMS has stated it will not correct participation status, so clinicians should verify PECOS now.
Yes. ASM participants are exempt from MIPS reporting for any year they are required to report under ASM.
- Quality: all measures in your cohort’s set are required, full calendar year, no measure selection. Heart Failure: 492, 008, 005, 236, 377, plus COST_HF_1. Low Back Pain: 238, 134, 128, 182 (replacing retired 220 under the CY2027 proposal), plus COST_LBP_1 and a newly proposed MRI Lumbar Spine claims measure.
- Cost: the cohort EBCM, calculated by CMS from claims. No submission required.
- Improvement Activities: 90-day period, attestation only, two required activities (IA-1 health-related social needs screening with primary care, IA-2 Collaborative Care Arrangements).
- Promoting Interoperability: 180-day period, CEHRT required, all objectives and measures required, no hardship exceptions.
Submission levels as finalized: Quality and Cost at the individual level, IA and PI at the TIN level.
March 31 following the close of the applicable ASM performance year, or a later date in that calendar year if CMS specifies one. For the 2027 performance year, that means March 31, 2028. This is the generally applicable submission deadline for ASM performance category data, and the CY2027 Proposed Rule aligns the new voluntary PRO data submission to the same date (§ 512.725(i)(1)(iv), 91 FR 43982-43983).
Three practical points:
- The cutoff is hard. CMS proposes to accept only timely submissions, corrections, and resubmissions, and to reject anything received after the deadline, in order to preserve the integrity and finality of scoring and the payment adjustment methodology. There is no grace period.
- You can correct and resubmit PRO data at any point up until the deadline (§ 512.725(i)(2)).
- If you believe CMS erred in determining whether you met the submission requirements or qualified for the scoring incentive, there is a separate timely error notice process (§ 512.725(i)(3) and § 512.755). That is post-deadline recourse, not an extension.
Note: this deadline reflects the CY2027 Proposed Rule and could change if CMS revises it before finalization.
CMS builds a virtual incentive pool per cohort: risk level × redistribution percentage × total participant Medicare Part B payments. For example, 9% × 85% × $1 billion = $76.5 million. CMS retains 15% for the Medicare Trust Fund and redistributes the remaining 85%. Risk levels are 9% for PY2027 and PY2028, then 10%, 11%, and 12%. Unlike MIPS, there is no fixed performance threshold. Scores are graded on a curve against cohort peers, so a score below the cohort median can produce a negative adjustment. Participants are notified through the ASM performance report.
Yes. Practices with 15 or fewer clinicians may report Quality at the TIN level, and all participants may report IA and PI at the TIN level. Small practices also receive 10 bonus points and solo practitioners receive 15. Under the CY2027 proposed rule, if CMS receives group-level quality data from a small practice it would score that submission for the whole practice and not also score an individual submission. CMS has said it will monitor small-practice performance and may revisit this flexibility.
P360 submits on your behalf. The steps are: determine your eligible providers, send P360 the participant list so your contract can be updated, discuss contract options to add the program, and select ASM in the P360 portal. Contracted TINs then push measure data the same way they currently push APP measures. For enrollment inquiries visit https://patient360.com/