ASM is a mandatory Medicare payment model that holds certain specialists financially accountable for how they manage two chronic conditions: heart failure and low back pain. It runs for five performance years, from January 1, 2027, through December 31, 2031.
CMS scores each participant in four categories:
Participants are compared against peers treating the same condition. Based on that comparison, they receive a positive, neutral, or negative adjustment to future Medicare Part B payments for professional services.
The low back pain cohort includes physicians in anesthesiology, pain management, interventional pain management, neurosurgery, orthopedic surgery, and physical medicine and rehabilitation. Cardiologists make up the heart failure cohort.
Two filters determine who is required to participate. First, a physician must have historically been attributed at least 20 qualifying episodes per year. Second, they must practice in one of the selected geographic areas, which cover roughly a quarter of the country’s metro areas. CMS’s preliminary list identified more than 6,600 physicians across 235 geographies.
Participation is tracked at the individual physician level, using the combination of the practice’s Tax ID and the physician’s NPI. That means two physicians in the same group can have very different results. Advanced practice providers are not individually selected, even when they support care for participating physicians.
The final list is not guaranteed to match the preliminary list CMS released in February. Check the final list directly rather than relying on what you saw earlier this year.
In the first two performance years, payment adjustments range from negative 9% to positive 9%. By the final year, the range widens to negative 12% to positive 12%.
The detail that matters most for planning is the lag. Adjustments are applied two years after each performance year, so 2027 performance drives 2029 payments. By the time a negative adjustment shows up on a remittance, the year that caused it is long over.
ASM also does not qualify as an Advanced APM, so participants do not receive the 5% APM incentive bonus. Practices already absorbing the fee schedule pressure we covered in [our August conversion factor post] should treat ASM as an additional layer of exposure, not a replacement.
It is tempting to hand ASM to whoever manages MIPS reporting. That undersells it. Much of what CMS will measure comes straight out of the claims and documentation your revenue cycle already touches.
The cost measure is built from claims. Episode-based cost measures look at spending tied to a patient’s condition over time. Those measures are risk adjusted using diagnosis information, so incomplete or unspecified diagnosis coding can make a complex patient look healthier, and a physician look more expensive, than they really are. Coding specificity is no longer only a denial prevention issue.
Quality data has to be captured, not just delivered. Functional status improvement cannot be scored if it is never recorded in a structured, reportable way. Intake and follow-up workflows need to collect it consistently.
Care coordination leaves a paper trail. ASM supports formal collaborative care arrangements with primary care physicians. Referral tracking and data sharing with those partners will need to be documented, not assumed.
Every Medicare Part B claim is in scope for the adjustment. The adjustment applies to professional services broadly, not just low back pain visits. A physician’s entire Medicare professional revenue stream is exposed.
Check the final list by NPI. Search the CMS ASM participant dataset for every physician in your practice who falls into an eligible specialty.
Size your exposure. For each participating physician, take annual Medicare Part B professional revenue and apply 9%. That is the realistic swing in either direction for the first adjustment year.
Review your existing cost data. If your physicians have been attributed low back pain episodes under MIPS, their performance feedback may already include cost measure results. Use that data to see where they stand before the model begins.
Audit diagnosis coding on low back pain encounters. Look specifically at unspecified codes and missing comorbidities that affect risk adjustment.
Confirm EHR capability. Make sure your certified EHR technology can support functional status capture and electronic data exchange with referring providers.
Use CMS’s onboarding resources. CMS has published a participant checklist, a portal user guide, and recorded webinars on the ASM model page.
Watch the November final rule. CMS is expected to release final regulations for the 2027 performance year in November, and details could still shift.
ASM rewards practices that treat documentation, coding, and data capture as part of patient care rather than a billing afterthought. The practices that start now will be the ones on the positive side of the adjustment.
If you want help determining which of your physicians are included, modeling your exposure, or auditing coding on low back pain episodes, schedule a discovery call or book a free audit with Pollux Systems.
