Need to Know Facts: CMS’s New Mandatory Ambulatory Specialty Model
CMS’s New Mandatory Ambulatory Specialty Model
The Center for Medicare & Medicaid Services (CMS) recently released the participant list for the new Ambulatory Specialty Model (ASM). This payment model gauges individual clinician-level performance around high-cost chronic conditions.
Included in this MANDATORY model is a dual-sided risk component designed to increase specialty provider accountability through the co-management of Medicare beneficiary’s care.
Important facts about this model and it’s potential impact:
- This is a MANDATORY dual-sided risk model: ASM participants will see escalating risk from 9-12% over the life of the model impacting ALL Medicare Part B claims reimbursement.
- Model performance begins on January 1, 2027 and runs through December 31, 2031.
- ASM participants are assessed at the individual provider level, not the tax ID, and participation is limited to certain clinician types. Selected clinicians will participate in one of two cohorts: Low Back Pain or Heart Failure
- Mandatory participation is based on several factors: these are related to claims billed; medical specialty type; episode thresholds; and geographic area criteria for model selection.
- Impacted Kentucky core-based statistical areas (CBSAs): Cincinnati/Northern Kentucky, Glasgow, Louisville Metro, Lexington-Fayette, Paducah, Pikeville, and Richmond/Berea.
- The framework of this model is based on a composite of the Quality Payment Program’s MVP and APP Tracks with components of Advanced APMs. Mandatory selection for this model may impact your individual clinical level reporting requirements for the QPP program.
Several Kentucky healthcare providers have been selected to participate in this MANDATORY model.
A list of selected providers can be found on the CMS Model website. Visit this link to determine if you are a required participant in the ASM
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.
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.
The New CMS Ambulatory Specialty Model: Is Your Practice Prepared?
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:
- Billing: You must bill claims under the Medicare Physician Fee Schedule
- 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
- Volume Threshold: You must meet a minimum of 20 episodes for your respective cohort
- 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.
Medicare Promoting Interoperability (PI) Program CY 2025 Reporting & Attestation Deadline
The Hospital Quality Reporting (HQR) System is now open
It is accepting calendar year 2025 Medicare Promoting Interoperability Program data submissions and attestations from eligible hospitals and critical access hospitals.
Kentucky hospitals participating in the Medicare Promoting Interoperability (PI) Program should be aware of important updates for Calendar Year (CY) 2025 reporting, including system availability, program changes, and the upcoming attestation deadline.
Expert advisors at the Kentucky Regional Extension Center are available to support hospitals throughout the reporting and attestation process. If you have questions, need clarification, or would like hands-on assistance, our team is ready to help.
HQR System Open for CY 2025 Submissions
The Hospital Quality Reporting (HQR) System is now open and accepting CY 2025 Medicare Promoting Interoperability Program data submissions and attestations for eligible hospitals and CAHs.
Important Deadline Reminder
The CY 2025 data submission and attestation deadline (including eCQM data) is:
Monday, March 2, 2026, at 11:59 p.m. Pacific Time
To avoid last-minute issues, hospitals are strongly encouraged to begin preparations early.
Kentucky REC Assistance Available
The Kentucky Regional Extension Center provides personalized technical assistance to help hospitals successfully meet Medicare Promoting Interoperability Program requirements. Our team can assist with:
• Understanding CY 2025 reporting updates
• Preparing and reviewing data submissions and attestations
• Verifying CMS EHR Certification IDs
• Reviewing measure requirements and exclusions
• Troubleshooting HQR submission issues
If your hospital has questions or needs assistance at any point in the process, we encourage you to contact the Kentucky REC. Early outreach can help prevent delays, ensure successful attestation, and avoid costly penalties.
Kentucky REC is here to support Kentucky hospitals every step of the way.
Call YOUR experts at Kentucky REC with all your questions. We’re here to help: 859-323-3090.
Want to be PCMH recognized but don’t have the resources?
Health Center Individualized Technical Assistance Program for PCMH Recognition
The Health Center Individualized Technical Assistance (TA) Program, funded by HRSA, offers personalized one-on-one support to HRSA-supported health centers and Look-Alikes that are not yet Patient-Centered Medical Home (PCMH) recognized, but are ready to pursue this important credential. Through this program, health centers receive individualized guidance from NCQA PCMH Certified Content Experts (CCEs) to help navigate PCMH requirements and successfully achieve Recognition. CCEs are supported by HRSA funding for their work with participating centers.
According to NCQA, Patient-Centered Medical Home recognition research shows this program improves quality and patient experience, and increases staff satisfaction, while reducing health care costs. It can also prepare your organization for building the foundation for Value-Based Care. The NCQA PCMH program is the most widely adopted program in the United States and has more than 10,000 recognized practices.
Who Is Eligible?
Health centers must:
- Be HRSA-supported or a Look-Alike
- Not currently hold PCMH Recognition
- Be prepared to begin the program within 45 days of approval
Participating centers are required to:
- Submit an Interest Form to NCQA
- Obtain an approved HRSA Notice of Intent (NOI)
- Select a Certified Content Expert (CCE)
If your health center chooses to participate and is approved, then you may select a PCMH Certified Content Expert (CCE) of your choice to assist during the recognition process.
The PCMH Certified Content Expert (CCE) Will Provide These Support Services:
- Clarify PCMH requirements
- Conduct self-assessments and gap analyses
- Develop an actionable plan for meeting PCMH standards
- Support enrollment and milestone completion
- Guide centers through NCQA tools and processes
- Help achieve and celebrate PCMH Recognition
The Kentucky REC’s PCMH Team Lead, Vance Drakeford, may be selected as the CCE from the available options. Vance has assisted over 50 healthcare organizations, including FQHC’s to achieve PCMH recognition.
Take the next step in improving services to your patients as well as employee satisfaction!
Questions? For more information on how to begin this process, or further details, contact YOUR experts by email at KYRec@uky.edu or call us at 859-323-3090. We’re here to help.
2025 Quality Payment Program Attestation Period Open
Centers for Medicare & Medicaid Services (CMS) recently opened the Quality Payment Program (QPP) data submission portal for the 2025 performance period. The portal will remain open until 8 pm ET Tuesday, March 31st, 2026.
Check out the mini video at the bottom of this blog post for a brief overview of what you need to do.
Eligible Clinicians must submit data for three of the four categories for the Merit-based Incentive Payment System Program (MIPS) to earn anywhere between a negative or positive 9% payment adjustment impacting Medicare Part B payments in calendar year 2027. If a clinician is eligible and submits no data, they will automatically receive a negative 9% payment adjustment.
Alternative Payment Model (APM) participants may submit data through the QPP Portal during this window.
Clinicians or their designee should verify that access to the organization’s QPP Portal is active and up to date. Users without a log-in to this portal will need to request access through the HCQIS Authorization Roles and Profile (HARP) system prior to submission by following the link here: https://qtso.cms.gov/access-forms/harp-account-registration
Data submission for each of the categories requires different time periods for data collection:
- Promoting Interoperability: minimum 180 consecutive days
- Improvement Activities: minimum 90 consecutive days
- Quality: full calendar year
- Cost: No submission, full calendar year from claims
Clinicians may use various methods for submitting data to each category:
- self-attestation
- uploading of QRDA-III or JSON files
- using a certified third-party registry
Each of these methods have specific rules that govern their use. Clinicians are encouraged to review those methods before attempting to attest.
Our advisors strongly recommend submitting data well in advance of the deadline to allow time for data validation or necessary updates within the QPP portal system.
In the coming weeks, the Kentucky REC advisors will be contacting clients to assist with data finalization, reviewing attestation checklists, and gathering audit support materials.
Not a client? Contact YOUR Experts at the Kentucky REC for all your QPP & APM questions. We’re here to help. Call us at 859-323-3090
Happy Holidays from Kentucky REC
SEASONS GREETINGS
QPP Webinar Dec 16: CMS 2026 Final Rule
QPP 2026 PFS & QPP Final Rule*
Webinar Date: December 16, 2025 @12pm
CMS released the highly anticipated 2026 Physician Fee Schedule (PFS) Final Rule on Nov 3rd — and the changes are significant.
From new Quality Payment Program (QPP) requirements to critical updates impacting MIPS Value Pathways (MVPs) and Alternative Payment Models (APMs), eligible clinicians will see meaningful shifts in reporting, participation, and performance expectations.
One of the most notable updates is the introduction of the new Ambulatory Specialty Model (ASM)—inclusion of specialists in outpatient and ambulatory care settings. ASM is designed to expand value-based care opportunities, improve quality measurement alignment for specialists, and offer new pathways to succeed in advanced payment arrangements.
OUR TEAM OF EXPERTS WILL WALK YOU THROUGH:
• Key QPP updates every organization must understand
• What’s changing within MVPs and APM participation
• How the Ambulatory Specialty Model will affect specialists and reporting options
• Action steps to prepare for 2026
Interested in learning more about QPP, attend upcoming webinars, or learn how our advisors can assist your practice in maximizing performance in the QPP or other value-based care programs? As a client, you receive exclusive access to our analysis of all aspects of the Quality Payment Program. To speak with the team on how we can best support you, feel free to contact us HERE.
*This webinar is for Kentucky REC contracted QPP clients only. If you are interested in this topic and would like to learn more about becoming a client, please contact us at (859) 323-3090 or email us at KYRec@uky.edu. We aim to be your trusted healthcare advisor!
Kentucky REC Annual Conference Oct 23 2025: Dr Tama Thé – The Promise of AI for Kentucky Healthcare
Dreams of Data—The Promise of AI for Kentucky Healthcare
Speaker: Dr Tama Thé, MD, Assistant Professor – Department of Emergency Medicine, UK HealthCare
Artificial intelligence is transforming medicine around the world. How can we make sure that Kentucky doesn’t get left behind? This presentation explores how we can harness AI to build a smarter, more connected healthcare system. We’ll look at how AI can improve diagnostic accuracy, reduce documentation burdens, and help address the physician shortage. We will highlight some of the innovative projects underway at UK HealthCare and get a peek of the broader vision driving the next wave of healthcare transformation.
Dr Tama Thé, MD
Tama Thé specializes in Pediatric Emergency Medicine and is an AI Research fellow with the National Board of Medical Examiners. He is leading AI initiatives both in healthcare at UKHC and across the state, as well as on the main campus at UK, and is the founder of the AI Incubator at the UK College of Medicine.
Questions? Contact us at Kentucky REC or call us at 859-323-3090.
Free Tobacco Cessation Referral Program for Providers — Limited Enrollment
A Healthier Kentucky Starts Here: Enroll in the Free Tobacco Cessation Referral Program
The Kentucky REC is partnering with the Kentucky Department of Public Health’s Tobacco Prevention and Cessation Program to help providers connect their patients to free, evidence-based support to help them quit using tobacco. Through this partnership, Kentucky REC will assist clinicians in setting up electronic referrals to National Jewish Health (NJH) — the nation’s leading tobacco cessation program. There will be no cost to providers, and no interface connection is required. Your EHR simply needs to allow the addition of direct mail addresses.
WHAT TO EXPECT
Our team will guide participating organizations through every step, integrating the e-referral process into clinical workflows and providing monthly check-ins to:
- Confirm electronic messages are successfully received by NJH
- Strengthen workflows to improve referral rates and efficiency
- Troubleshoot when referrals aren’t being completed or returned
This is a grant-sponsored opportunity, and participation is limited to the first four enrolled organizations.
Interested? Need more information? Contact us! Spaces will fill quickly.
Kentucky REC Annual Conference Oct 23: HIE-Speed Ahead – Connecting Care Smarter
HIE-Speed Ahead: Connecting Care Smarter
Speaker: Andrew Bledsoe, Kentucky Cabinet for Health and Family Services
Get ready to accelerate into the future of health information technology! Andrew Bledsoe of the Kentucky Cabinet for Health and Family Services introduces KHIE’s new HIE system and its enhanced capabilities, designed to make data exchange faster, smarter, and more seamless than ever. We’ll explore how these upgrades improve care coordination, strengthen connections, and empower providers with the right information at the right time.
About Andrew Bledsoe, Deputy Inspector General, Office of Inspector General, Kentucky Cabinet for Health and Family Services
The intersection of health information technology with quality care delivery has provided Andrew Bledsoe with a unique perspective over his two plus decades in healthcare. Starting his career in a regional hospital, he quickly learned the challenges in healthcare, especially rural medicine, and began investing in the concept of leveraging health information technology to improve outcomes for patients.
His current appointment as the Deputy Inspector General for the Office of the Inspector General within the Cabinet for Health and Family Services primarily focuses on implementing the KHIE Strategic and Operational Plan, promoting the statewide exchange of patient health information, spearheading a number of new services designed to improve care coordination, and offer new avenues to reduce reporting burdens and foster inter-agency collaboration.
Questions? Contact us at Kentucky REC or call us at 859-323-3090.
