The Centers for Medicare & Medicaid Services (CMS) recently announced a new payment initiative that will require certain cardiologists to participate in a value-based reimbursement model focused on heart failure care. This program, known as the Ambulatory Specialty Model (ASM), is scheduled to begin January 1, 2027 and will run through December 31, 2031.

The announcement is a signal of Medicare’s continued push toward value-based care models, in which physician reimbursement is increasingly tied to quality metrics and cost management rather than just the volume of services provided.

Overview of the Ambulatory Specialty Model

The ASM is designed to improve the prevention and management of chronic diseases in outpatient settings, with an initial focus on heart failure and lower back pain. CMS has indicated that the program is intended to reduce avoidable hospitalizations, improve care coordination, and lower overall Medicare spending.

Heart failure represents a particularly significant target for cost containment efforts. Estimates suggest that heart failure care costs the U.S. healthcare system approximately $179.5 billion annually, making it one of the most expensive chronic conditions treated within the Medicare population.

Under the ASM, certain specialists who frequently treat Medicare patients with these conditions will be required to participate in the program if they meet specified eligibility criteria.

Who Will Be Required to Participate

CMS has released a list identifying approximately 2,600 cardiologists who will be required to participate in the heart failure portion of the ASM. See the full list here.

Physicians were selected based on several criteria, including:

  • Billing under the Medicare Physician Fee Schedule
  • Practicing in CMS-designated geographic regions
  • Having a specialty designation in general cardiology
  • Historically treating at least 20 heart failure episodes per year

CMS will evaluate eligibility using data from two years prior to a performance year. For example, CMS will use 2025 claims data to determine eligibility for the 2027 performance year.

The program will also include more than 4,000 physicians treating lower back pain, reflecting CMS’s broader effort to target high-cost chronic conditions.

Payment Adjustments Under the Model

Beginning in 2028, participating physicians will have their Medicare Part B payments adjusted based on their performance within the model.

For the first two payment years (2028 and 2029), payment adjustments will range from –9% to +9%, with the potential for larger adjustments in later years.

Notably, these adjustments apply at the individual physician level and affect all of the physician’s Medicare Part B claims, not just claims associated with heart failure treatment.

How Performance Will Be Measured

The ASM builds upon the existing Merit-based Incentive Payment System (MIPS) framework and evaluates physicians across several performance domains, including:

  • Quality of care
  • Care improvement activities
  • Cost of care
  • Interoperability and data sharing

A significant portion of a physician’s performance score (reportedly 50%) will be tied to an episode-based cost measure related to heart failure treatment.

Questions and Concerns Raised by Professional Societies

Several cardiology organizations have raised questions about the design and implementation of the program.

The American College of Cardiology (ACC) has submitted comments to CMS identifying potential operational challenges, including concerns about the program’s focus on individual physician performance rather than team-based care models that are common in cardiology.

The American Society of Nuclear Cardiology (ASNC) has also encouraged members to review the CMS participant list and report whether they were included, noting that the organization is still working to understand the program’s full impact on its membership.

Professional organizations have also requested additional transparency from CMS regarding the data that will be used to determine physician performance under the model.

What This Means for Physicians

Although the ASM initially targets cardiologists and physicians treating lower back pain, the model reflects a broader policy trend within Medicare.

Over the past decade, CMS has steadily expanded value-based payment models, shifting reimbursement toward programs that emphasize cost control, prevention, and measurable outcomes.

Physicians should expect that similar programs will continue to expand across specialties as CMS pursues its long-term goal of transitioning a larger share of Medicare spending into value-based payment arrangements.

For physicians identified as ASM participants, reviewing the program requirements and monitoring future CMS guidance will be important as implementation approaches.

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Photo of Adam Appleberry Adam Appleberry

Adam is a healthcare attorney focusing on compliance, credentialing, peer review, reimbursement, contracts, HIPAA, and telehealth issues for physicians.

As a former business executive and U.S. Army officer, Adam brings a unique, real-world perspective to the practice of law. He focuses his legal…

Adam is a healthcare attorney focusing on compliance, credentialing, peer review, reimbursement, contracts, HIPAA, and telehealth issues for physicians.

As a former business executive and U.S. Army officer, Adam brings a unique, real-world perspective to the practice of law. He focuses his legal practice on helping physicians, medical professionals, and healthcare organizations proactively address legal and regulatory challenges—whether forming a private practice, navigating employment and partnership agreements, or preparing for a sale or acquisition.