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.
CMS recently released a preliminary list of participants based on CY 2024 data, identifying approximately 4,000 Low Back Pain cohort participants. Notably, CMS presumes that the majority of individuals determined eligible based on CY 2024 data will remain eligible based on CY 2025 data. Based on a preliminary analysis, AAPM&R estimates that nearly 25% of participants in the model are PM&R physicians.
CMS is expected to release an updated participant list for the CY 2027 performance year in Summer 2026, based on CY 2025 data. In the meantime, CMS encourages identified participants to complete the ASM Participant Contact Information Form to ensure they receive up-to-date program information.
Who is Included in the ASM?
Participation in ASM is mandatory for all clinicians who meet the following eligibility criteria:
- Bill under the Medicare Physician Fee Schedule (PFS).
- Are identified as belonging to one of the CMS-selected specialties. For the Low Back Pain Cohort, this includes PM&R, Interventional Pain Management, Pain Management, Anesthesiology, Neurosurgery, and Orthopedic Surgery. Specialty designation is based on the code reflected on the plurality of a clinician’s Medicare Part B claims from two years prior to the performance year (e.g., CY 2027 eligibility would be based on CY 2025 claims data). Since Medicare does not assign specialty codes to non-physician practitioners, only physicians will be included in ASM.
- Attributed at least 20 episodes under the applicable episode-based cost measure (for the Low Back Pain cohort, this would be the Low Back Pain episode-based cost measure (EBCM) (COST_LBP_1) used in MIPS) in the two years prior to the performance year.
- Are located in one of the selected mandatory geographic areas. CMS will base this on the zip code assigned to each EBCM episode attributed to the clinician.
How Participation is Determined
Notably, ASM participation is at the individual clinician level, as defined by the combination of a clinician’s unique tax identification number and their national provider identification (or TIN-NPI.)
Since eligibility is assessed at the TIN–NPI level, clinicians may qualify for ASM under multiple TINs. If this occurs, each TIN-NPI combination would be treated as a separate participant and the clinician would be required to report separately for each TIN-NPI that meets ASM eligibility.
Additionally, some clinicians may be eligible under ASM through one TIN-NPI combination but would still be required to participate in MIPS under a different TIN-NPI combination that does not qualify for ASM.
Participation Over Time
Once determined to be eligible for ASM, clinicians will remain participants for the duration of the model. CMS will reassess ASM participant eligibility annually.
If an ASM participant meets the model eligibility criteria, the participant must meet ASM model requirements, and is exempt from MIPS reporting requirements, if applicable.
If an ASM participant does not meet the ASM participant eligibility criteria for a subsequent ASM performance year, they will remain an ASM participant but will not be required to meet ASM requirements for the applicable performance year and will be required to participate in MIPS, if applicable.
CMS plans to evaluate participant eligibility on an annual basis using data from two years prior to each performance year. To illustrate, claims data from 2025 will determine eligibility for participation in 2027.