Explore the ASM
Disclaimer: CMS has proposed adjustments to the Ambulatory Specialty Model in the Medicare Physician Fee Schedule proposed rule. This page will be updated in November when CMS finalizes its ASM policies. Contents of these pages reflect current ASM policies as finalized in November 2025.
How does ASM differ from MIPS?
Overview of Comparison
CMS has modeled ASM off the MIPS Value Pathways (MVPs), which is a newer reporting pathway in MIPS. However, ASM does differs from MVPs in several key ways:
- Fixed measure set: ASM participants are required to report on a fixed set of measures and activities specific to their cohort. In contrast, MVPs allow clinicians to select from a menu of measures.
- Condition-specific cohort comparisons: Performance is evaluated within cohorts, meaning clinicians are compared to peers participating in the same ASM cohort, not to all MIPS-eligible clinicians broadly.
- Scoring methodology: Quality and cost carry greater weight under ASM, each accounting for 50% of the ASM final score.
- Individual-level reporting: Most ASM participants will be required to report quality measures as individual clinicians, even if they have historically reported MIPS through a group or APM entity.
- Fewer exemptions: ASM does not include the same exemptions or exceptions as MIPS. As a result, clinicians who would otherwise be exempt from MIPS (e.g., Qualifying Participants in an Advanced APM or QPs) are still required to participate if they meet model eligibility. Additionally, clinicians who have special status under MIPS (e.g., small practice) may now be held accountable for certain ASM performance categories that may have been previously reweighted under MIPS (e.g., Promoting Interoperability).
- Greater financial risk: While ASM initially places up to 9% of Medicare Part B payments at risk (similar to MIPS), this risk increases to as much as 12% by performance year 2031.
CMS has indicated that it believes ASM represents an improvement over MIPS by producing quality scores and payment adjustments that more accurately reflect clinician performance through condition-specific measures and peer comparisons. Looking ahead, evaluations from ASM may inform future MIPS policies, especially as CMS continues to contemplate a broader shift toward mandatory MVPs in the future.