CMS’s New Mandatory Ambulatory Specialty Model: Initial Participation List Announced

The Centers for Medicare & Medicaid Services (CMS) recently released the Initial Participation list for clinicians required to take part in the newly finalized Ambulatory Specialty Model (ASM) — a significant shift in how specialty care is delivered and reimbursed in Traditional Medicare.

Several Kentucky healthcare providers have been selected to participate in this MANDATORY model. Visit this link to determine if you are a required participant in the ASM

If you are a participant in this model, you have certain action items due by February 17th, 2026.

These impact registration and limit access to critical information through the ASM Participant Portal. Here is the ASM Participant Contact Information Form.
If you are a specialist managing patients with heart failure or low back pain, the time to understand your obligations is now.

Click this link to visit CMS’s Ambulatory Specialty Model website to learn more or contact your Kentucky REC advisor at 859-323-3090 to learn about our ASM operational and strategic support services.

What is the ASM?

The ASM is designed to improve the co-management of Traditional Medicare beneficiaries while driving down costs within defined clinical episodes. Unlike many prior payment models, this is an individual provider-level model. It places the responsibility for cost and quality directly on the MDs and DOs who manage high-cost chronic conditions.

Are You Required to Participate?

Participation is mandatory for providers who meet four specific criteria:

1. Billing: You must bill claims under the Medicare Physician Fee Schedule
2. Specialty Focus: You are identified by your TIN/NPI in one of two primary cohorts:
   • Heart Failure Cohort:Cardiology
   • Low Back Pain Cohort: Anesthesiology, Orthopedics, Orthopedic Surgery, Interventional Pain Management, Pain Management, Physical Medicine and Rehabilitation, and Neurosurgery
3. Volume Threshold: You must meet a minimum of 20 episodes for your respective cohort
   
4. Geography: You must be located in one of the CMS-identified mandatory geographic areas

Key Timeline and Risk Structure

The ASM is a long-term commitment to value-based care, requiring participants to navigate escalating financial stakes.

Duration: Five years, beginning January 1, 2027, and concluding December 31, 2031.
Escalating Risk: Participants will face a dual-sided risk profile starting at 9% and increasing to 12% over the life of the model.
The Bottom Line: The ASM represents a move toward granular accountability. Specialists are no longer on the sidelines of value-based care—they are now a vital part of it.

Questions about eligibility and practice impacts from this new MANDATORY payment model? Contact YOUR Experts at the Kentucky REC for all your ASM questions. Call us at 859-323-3090 or email us kyrec@uky.edu.