Medicare's Ambulatory Specialty Model (2027): What It Means for Cardiology, Spine and Pain Physician Pay
Medicare's mandatory Ambulatory Specialty Model starts Jan 1, 2027 for 5,556 cardiology, spine and pain physicians: who's in, how it scores, and ±9% in dollars.
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Key takeaways
- Medicare's Ambulatory Specialty Model (ASM) starts January 1, 2027. It is mandatory, with no opt-out, for 5,556 physicians on CMS's final list: 2,215 cardiologists and 3,341 spine, pain, orthopedic, anesthesia and PM&R physicians.
- Your 2027 performance moves your 2029 Medicare Part B payments by up to ±9%, rising to ±12% by 2033. On $300,000 of Part B payments, that is up to $27,000 either way in the first year.
- The pool is not even: in 2027 CMS pays back only about 85 cents in bonuses for every dollar of cuts, so the group as a whole loses money.
- Quality and cost each count for half of the score. Missing the two required primary-care activities or the interoperability requirements only subtracts points, and failing to report quality data brings the maximum cut.
- ASM replaces MIPS for participants. Check the list on data.cms.gov now, and if you're employed, ask how your contract treats Medicare adjustments.
Most Medicare payment changes hit every physician at once: the conversion factor, a new code, a MIPS threshold. The Ambulatory Specialty Model is different. It applies to a few thousand named physicians in randomly chosen markets, it grades each of them against their peers on one condition, and it moves their Medicare pay up or down by as much as 12%. If you are a cardiologist or a spine or pain physician, this guide covers whether you are in it, what it can cost or pay you, and what to do before it starts.
For the conversion factor and the rest of next year's Medicare rule, see our 2027 Medicare physician fee schedule guide.
What the Ambulatory Specialty Model is
The ASM is a CMS Innovation Center payment model, finalized in the 2026 Medicare physician fee schedule rule on October 31, 2025. It holds individual specialists financially accountable for how well, and how expensively, their Medicare patients with two common chronic conditions are cared for: heart failure and low back pain.
It borrows MIPS's four categories (quality, cost, improvement activities and promoting interoperability) but scores them differently, compares you only with other physicians treating the same condition, and uses a larger, two-sided payment adjustment. For the years you are in it, it replaces MIPS. It runs for five performance years, 2027 through 2031.
Who is in it
A physician is in the model for a given year when all three of these are true:
- Specialty. Cardiology for the heart failure cohort. Anesthesiology, pain management, interventional pain management, neurosurgery, orthopedic surgery or physical medicine and rehabilitation for the low back pain cohort. CMS uses the specialty code on most of your Medicare Part B claims, so a cardiologist who bills mainly as interventional cardiology or electrophysiology is generally not in the heart failure cohort.
- Location. A service location in one of the 235 metropolitan areas and divisions CMS selected at random, roughly a quarter of the 935 nationwide. The draw was stratified by Medicare spending, episode volume and metro status, so it includes both expensive and inexpensive markets.
- Volume. At least 20 attributed episodes of the condition, using Medicare's episode-based cost measures. Eligibility for 2027 is based on 2025 claims.
Inclusion is decided per physician, by NPI and billing TIN, not per practice, so two partners in the same group can be treated differently. CMS posted a preliminary list of 6,637 clinicians in February 2026 and the final 2027 list in September 2026: 5,556 physicians, with no one added who wasn't on the preliminary list.
To check: open the ASM Participants dataset on data.cms.gov and search by NPI or name. Each record shows the cohort and the performance years you must meet the model's requirements. Practice managers can search by organization name to see everyone in a group at once.
Timeline and risk levels
Each year's performance sets the payment adjustment two years later. The “risk level” is the largest cut or bonus possible that year.
| Performance year | Adjusts Part B payments in | Maximum cut or bonus |
|---|---|---|
| 2027 | 2029 | ±9% |
| 2028 | 2030 | ±9% |
| 2029 | 2031 | ±10% |
| 2030 | 2032 | ±11% |
| 2031 | 2033 | ±12% |
- Adjusts Part B payments in
- 2029
- Maximum cut or bonus
- ±9%
- Adjusts Part B payments in
- 2030
- Maximum cut or bonus
- ±9%
- Adjusts Part B payments in
- 2031
- Maximum cut or bonus
- ±10%
- Adjusts Part B payments in
- 2032
- Maximum cut or bonus
- ±11%
- Adjusts Part B payments in
- 2033
- Maximum cut or bonus
- ±12%
The first two years carry the same ±9% as MIPS. After that, the stakes are higher than MIPS has ever been.
What it means in dollars
The adjustment applies to your Medicare Part B payments for your own services in the payment year. The table shows the most you could lose or gain at three levels of yearly Part B payments. Most participants will land well inside these limits, because CMS deliberately designed the scoring to damp results at the extremes.
| Yearly Medicare Part B payments | 2029 (±9%) | 2030 (±9%) | 2031 (±10%) | 2032 (±11%) | 2033 (±12%) |
|---|---|---|---|---|---|
| $150,000 | ±$13,500 | ±$13,500 | ±$15,000 | ±$16,500 | ±$18,000 |
| $300,000 | ±$27,000 | ±$27,000 | ±$30,000 | ±$33,000 | ±$36,000 |
| $500,000 | ±$45,000 | ±$45,000 | ±$50,000 | ±$55,000 | ±$60,000 |
- 2029 (±9%)
- ±$13,500
- 2030 (±9%)
- ±$13,500
- 2031 (±10%)
- ±$15,000
- 2032 (±11%)
- ±$16,500
- 2033 (±12%)
- ±$18,000
- 2029 (±9%)
- ±$27,000
- 2030 (±9%)
- ±$27,000
- 2031 (±10%)
- ±$30,000
- 2032 (±11%)
- ±$33,000
- 2033 (±12%)
- ±$36,000
- 2029 (±9%)
- ±$45,000
- 2030 (±9%)
- ±$45,000
- 2031 (±10%)
- ±$50,000
- 2032 (±11%)
- ±$55,000
- 2033 (±12%)
- ±$60,000
The pool is tilted against participants. Bonuses are funded from the cuts within each cohort, and for 2027 CMS pays out only 85% of that pool as bonuses. The other 15% goes to the Medicare Trust Fund. So for every $100 taken from below-average physicians, above-average physicians share about $85. Doing better than your peers is not optional if you want to come out ahead.
How the score works
Each participant gets a final score from 0 to 100 for each performance year:
| Part of the score | How it counts |
|---|---|
| Quality | 50% of the score. Five measures for each cohort, mostly existing MIPS measures. |
| Cost | 50% of the score. The heart failure or low back pain episode-based cost measure, calculated by CMS from claims; you submit nothing. |
| Improvement activities | Deduction only: up to 20 points off for missing the two required activities (10 points each). |
| Promoting interoperability | Deduction only: up to 10 points off for not meeting the certified-EHR measures. |
| Complex patients | Up to 10 extra points, based on patients’ risk scores and the share who are dual-eligible. |
| Small practices | Extra points for practices of 15 or fewer clinicians, subject to the 100-point cap. |
- How it counts
- 50% of the score. Five measures for each cohort, mostly existing MIPS measures.
- How it counts
- 50% of the score. The heart failure or low back pain episode-based cost measure, calculated by CMS from claims; you submit nothing.
- How it counts
- Deduction only: up to 20 points off for missing the two required activities (10 points each).
- How it counts
- Deduction only: up to 10 points off for not meeting the certified-EHR measures.
- How it counts
- Up to 10 extra points, based on patients’ risk scores and the share who are dual-eligible.
- How it counts
- Extra points for practices of 15 or fewer clinicians, subject to the 100-point cap.
The two required improvement activities both tie the specialist to the patient's primary care:
- Connect patients to primary care and screen for social needs. Confirm each patient in the model has a primary care clinician (and help them find one if not), send visit information back, and make sure an annual health-related social needs screening is done, by you or the primary care practice.
- A collaborative care arrangement. Sign at least one written agreement with a primary care practice that shares your patients, setting expectations for communication and co-management.
Two rules carry the most financial weight. Failing to submit quality data triggers the maximum cut, according to analyses of the rule. And a physician who reports but can't be scored on quality or cost, because they have fewer than 20 episodes or 20 cases in the performance year, gets no final score and a neutral adjustment.
Cardiology vs. spine and pain
Heart failure cohort (2,215 cardiologists)
The quality measures, as finalized, are unplanned cardiovascular admissions for heart failure patients, beta-blocker therapy and ACE inhibitor, ARB or ARNI therapy for reduced ejection fraction, blood pressure control, and functional status assessment. On cost, hospital admissions and readmissions drive most of the variation, so the practices that score well on cost will mostly be the ones that keep heart failure patients out of the hospital: fast follow-up after discharge, medication titration and remote monitoring.
Low back pain cohort (3,341 physicians)
The quality measures, as finalized, are lumbar MRI use for low back pain, high-risk medications in older adults, depression screening and follow-up, BMI screening and follow-up, and functional status change for low back impairments. Cost covers the whole episode, so imaging, injections, surgery and opioid prescribing all count against you. For physicians whose income depends on procedure volume, this is the first Medicare program that directly rewards doing fewer of them for the same patient population.
Anesthesiology, orthopedics and neurosurgery groups should note that only physicians who meet the episode threshold are included, which usually means the pain and spine physicians in a group, not every anesthesiologist or surgeon. Our cardiology, anesthesiology, orthopedic surgery and neurosurgery salary guides cover what these specialties earn today.
Employed physicians vs. practice owners
The adjustment lands on the Medicare claims billed for your work, which means it lands on whoever owns those claims.
- Practice owners and partners feel it directly: a cut comes out of collections, and therefore out of distributions.
- Employed on pure wRVU pay: no direct effect, since wRVUs don't change with Medicare adjustments. Expect your employer to care a great deal about your score anyway, and to ask you to change workflows.
- Employed on collections, net revenue or a quality bonus: you may share the result. Read the compensation section of your contract for language about payer adjustments, MIPS or “value-based” payments, and ask how the employer will treat ASM. Our wRVU guide and contract negotiation guide explain what to look for.
If you are negotiating a new job in a selected market, it is reasonable to ask that ASM adjustments be excluded from any collections-based pay for the first years, while the model and its benchmarks are new.
Changes proposed for 2027
CMS proposed a set of ASM changes in the 2027 physician fee schedule proposed rule on July 14, 2026. The final rule is expected around November 1, so these may change. Among them:
- Rural adjustment: five extra points on the final score for rural participants, who would keep the small-practice and complex-patient adjustments.
- Patient-reported outcomes: five extra quality points for voluntarily submitting patient-reported outcome data such as PROMIS.
- Low back pain measures: a new claims-based lumbar spine imaging measure, and a functional outcome assessment process measure in place of the functional status change measure.
- Staying in: a clinician selected for any performance year would remain a participant for the rest of the model unless terminated under specific rules.
- Exceptions: a permanent exception for certain heart failure specialists who change their specialty designation, and a formal process for TIN changes and other qualifying circumstances.
We will update this guide when the final rule is published.
What to do before January 1
- Check the list. Search data.cms.gov for every cardiologist and spine or pain physician in your group, by NPI.
- Update your contact information with CMS using the ASM participant contact form, so model notices and reports reach you.
- Plan the quality reporting. Choose how you will submit the five measures (EHR, registry or another method) and confirm you can reach the data-completeness requirement. Not reporting is the one sure way to take the maximum cut.
- Sign a collaborative care arrangement with at least one primary care practice you share patients with, and set up the primary care and social-needs workflow. Each missing activity costs 10 points.
- Confirm your EHR meets the interoperability requirements (certified EHR technology), worth up to 10 points.
- Estimate your exposure. Multiply your yearly Part B payments by the risk level; that is your range for 2029. If you're employed, ask how your contract treats it.
- Watch the final rule around November 1 for the 2027 changes above.
Frequently asked questions
Can I opt out of the Ambulatory Specialty Model?
How much can the Ambulatory Specialty Model cut my Medicare pay?
Do ASM participants still report MIPS?
How do I know if I am in the Ambulatory Specialty Model?
Does the Ambulatory Specialty Model affect employed physicians?
Which specialties are in the Ambulatory Specialty Model?
Sources
- CMS Innovation Center: Ambulatory Specialty Model, model fact sheet, frequently asked questions and improvement activities toolkit.
- CMS, ASM participant selection methodology (September 2026) and ASM Participants data dictionary.
- Federal Register, CY 2027 physician fee schedule proposed rule (July 16, 2026).
- American College of Cardiology, CMS releases final ASM participant list for 2027 (September 15, 2026); ASRA, preliminary participant list (February 2026).
- Final-rule summaries: Epstein Becker Green, Benesch, Milliman (scoring, measures and the redistribution percentage), and the American College of Surgeons Bulletin.
- Proposed 2027 changes: Applied Policy; American Society of Anesthesiologists.
- Participant counts by cohort: VBCA.
Read next: the 2027 Medicare physician fee schedule guide, or how pay is measured in our wRVU guide.
Disclaimer: This guide summarizes the Ambulatory Specialty Model as finalized in the CY 2026 Medicare physician fee schedule rule and the changes CMS proposed in July 2026, using CMS materials and published analyses of the rule. Some scoring details, including the small-practice adjustment and how scores convert to payment adjustments, are described differently across sources, and the 2027 final rule may change the model. Dollar figures are illustrations of the maximum adjustment, not predictions. Confirm your status and requirements with CMS (data.cms.gov and the ASM help desk) and your billing or compliance team. This guide is for educational purposes only and is not legal, billing or financial advice. MedMoneyGuide has no affiliate or advertising relationships with the organizations cited.

About the Author
Joshua Dunigan, DO | Family Medicine Resident & Founder
I'm a family medicine resident physician in Des Moines, Iowa (class of 2027). I founded MedMoneyGuide to give physicians specialty-specific financial guidance, with sources you can check.