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 is Performance Measured in the ASM?
Under ASM, participants are assessed across four performance categories – Quality, Cost, Improvement Activities, and Promoting Interoperability – which is similar to the structure of MIPS. However, ASM places greater weight on quality and cost, with both categories accounting for 50% of the participant’s ASM final score. While not directly weighted in the ASM final score, both the Improvement Activities and Promoting Interoperability categories could negatively impact a participant’s final score depending on performance. For example, if a participant does not receive full credit in either category, their overall ASM final score may be subject to a downward adjustment.
Quality Performance Category
Summary Included on Main Page: ASM Quality Performance Category. ASM participants are required to report all cohort-specific quality measures, with the exception of administrative claims-based measures, which will be calculated directly by CMS. Quality measures for the Low Back Pain Cohort are discussed below. Unless a participant is part of a small practice, the physician must report quality measures the TIN-NPI (individual clinician) level. However, small practices have the flexibility to report at the TIN (or group) level.
ASM Quality Performance Category for Low Back Pain
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Domain
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Prevention Category
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Measure
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Collection Type(s)
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Evidence-based Care and Outcomes
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Adverse events andacute utilization
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Use of High-Risk Medications in Older Adults (Q238)
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eCQM, MIPS CQM
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Evidence-based Care and Outcomes
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Risk reduction/absenceof disease
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Preventive Care and Screening: Screening for Depression and Follow-Up Plan (Q134)
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eCQM, MIPS CQM
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Evidence-based Care and Outcomes
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Risk reduction/absence of disease
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Preventive Care and Screening: BMI Screening and Follow-Up Plan (Q128)
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eCQM, MIPS CQM
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Patient Reported Outcomes and Experience
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Function/healthstatus/wellbeing
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Functional Status Change for Patients with Low Back Impairments (Q220)[1]
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MIPS CQM
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Performance is evaluated relative to peers within the same cohort, with benchmarks established separately for each measure and collection type using participant-reported data. Participants will receive between 1 and 10 achievement points per measure based on their performance relative to the benchmarks. To be scored, participants must meet certain data completeness and case minimum requirements. [MM1] A participant’s overall Quality Performance Score is calculated by dividing the total achievement points earned across all reported measures by the total possible points, yielding a percentage-based score.
Cost Performance
The ASM Cost Performance Category is scored based on the MIPS episode-based cost measure (EBCM) specific to each cohort. Participants in the Low Back Pain Cohort will be held accountable for the Low Back Pain EBCM (COST_LBP_1) measure.
Cost benchmarks are set based on the cost measure performance of ASM participants during the performance year itself. Participants are then assigned between 1 and 10 achievement points based on the benchmark range in which their performance falls.
To receive a cost performance score, participants must have at least 20 attributed episodes at the TIN-NPI level. Participants who do not meet this case minimum will receive no score in the Cost Performance Category and will instead receive a neutral payment adjustment for the applicable ASM payment year, regardless of performance in any of the other performance categories.
Improvement Activities Performance Category
The ASM Improvement Activities Performance Category applies a uniform set of activities across all ASM participants, regardless of cohort.
These activities focus on care coordination, integration of specialty and primary care, and addressing the health-related social needs of patients.
Participants must complete these activities during a continuous 90-day period within the performance year, with data submitted at the TIN level.
Failure to attest to required improvement activities may result in a reduction to the participant’s ASM final score. For example, failure to report one required activity will result in a 10-point reduction, while failure to report two activities will result in a 20-point reduction.
ASM Improvement Activities
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Improvement Activity
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Description
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Connecting to Primary Care and Ensuring Completion of Health-Related Social Needs Screening (IA-1)
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Must have evidence of processes, workflows, or technology that require the ASM Participant to do all of the following:
- Confirm the ASM beneficiary has access to primary care services and, if not, assist the ASM beneficiary in finding a clinician who provides primary care services.
- Communicate relevant information back to the ASM beneficiary's primary care provider following the ASM beneficiary's visit with the ASM participant.
- Determine whether the ASM beneficiary has received an annual health-related social needs screening in the primary care setting and, if not, encourage the primary care services provider to conduct the screening or allow the ASM Participant to conduct the health-related social needs screening.
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Establishing Communication and Collaboration Expectations with Primary Care using Collaborative Care Arrangements (IA-2):
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Must do all of the following:
- Have at least one executed collaborative care arrangement between a primary care practice with which the ASM participant shares ASM beneficiaries.
- The collaborative care arrangement must include collaborative efforts related to at least three of the following five elements:
- Data sharing, which includes setting expectations for bi-directional sharing of patient information between the parties to the collaborative care arrangement, including but not limited to test results, treatment plans, and follow-up recommendations.
- Co-management, which includes defining co-management approaches, where the parties to the collaborative care arrangement work together to furnish complementary care for patients with complex or chronic conditions.
- Transitions in care planning, which includes defining protocols for seamless transitions of care between ASM participants, the primary care practice, or different care settings.
- Closed-loop communication, such as clearly articulated processes enforcing parameters on how ASM beneficiaries may be referred between the parties to the collaborative care arrangement.
- Care coordination integration comprised of structured processes to embed care coordination processes into the ASM participant's practice workflow.
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ASM Promoting Interoperability Performance
To receive a score in this category, participants must demonstrate meaningful use of certified electronic health record technology (CEHRT) and satisfy applicable reporting requirements.
This includes attesting to required measures and reporting on activities that support interoperability.
Importantly, clinicians who would typically qualify for exemptions under MIPS (e.g., hospital-based or small practices) are still required to meet Promoting Interoperability requirements under ASM.
ASM Promoting Interoperability Objectives and Measures
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Objectives
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Measures
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Available Points
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e-Prescribing
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e-Prescribing
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1–10 points
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Query of PDMP
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10 points
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Health InformationExchange (HIE)
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Option 1:
• Support Electronic Referral Loops bySending Health Information
• Support Electronic Referral Loops byReceiving and Reconciling HealthInformation
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1–15 points
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1–15 points
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Option 2: HIE Bi-Directional Exchange
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30 points
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Option 3: Enabling Exchange underTECFA
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30 points
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Provider to PatientExchange
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Provide Patients Electronic Access toTheir Health Information
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1–25 points
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Public Health andClinical DataExchange
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Report to the following public health orclinical data registries:
1. Immunization Registry Reporting
2. Electronic Case Reporting
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25 points for the objective
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Option to report one of the following:
• Public Health Registry Reporting
• Clinical Data Registry Reporting
• Syndromic Surveillance Reporting
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No bonus points
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Participants earn points by meeting reporting requirements, and the final score is calculated based on the proportion of points earned out of total available points.
Performance in this category may result in a downward adjustment of up to 10 points in the final ASM score.
Additional Adjustments
ASM participants may be eligible for additional scoring adjustments:
- Complex Patient Bonus: up to 10 points based on patient risk and dual-eligible status
- Small Practice Adjustment:
- 10 points for practices with ≤15 clinicians
- 15 points for solo practitioners