CMS Ambulatory Specialty Model FAQ for Cardiology Practices

The Ambulatory Specialty Model (ASM) is a mandatory CMS Innovation Center model that will adjust future Medicare Part B payments for selected specialists based on performance.

For cardiology, ASM focuses on specialists who frequently treat Original Medicare beneficiaries with heart failure in outpatient settings. The model is designed to improve chronic disease management, strengthen coordination between specialists and primary care, and reduce avoidable hospitalizations and unnecessary spending.

ASM begins January 1, 2027, and runs through December 31, 2031.

The model includes five performance years. Because future Medicare Part B payment adjustments are based on performance, cardiology practices should use 2026 to confirm participation, understand baseline performance, and address operational gaps before the first performance year begins.

Yes, ASM is mandatory for selected cardiologists and other eligible specialists who meet CMS participation criteria.

Participation is based on CMS methodology that considers factors including specialty, geographic area, and attributed episode volume. A cardiologist does not voluntarily enroll in ASM if CMS has selected that clinician for participation.

Search the CMS ASM participant dataset using the clinician’s National Provider Identifier, or NPI.

CMS publishes participant information at the individual clinician level. Cardiology groups should check each potentially eligible cardiologist rather than assume the entire practice is included or excluded.

Because participant information may be updated, practices should continue monitoring official CMS communications before the 2027 performance year.

Not necessarily. ASM participation is determined at the individual clinician level, so some cardiologists in a group may participate while others do not.

A cardiology practice could have two or three physicians subject to ASM requirements while other providers in the same organization are not selected participants.

This creates an important operational question: how should the practice standardize heart failure care across the organization while still tracking ASM-specific performance for participating clinicians?

Yes. A cardiology group may include both ASM participants and non-participants.

Practices should be prepared to identify participating clinicians, understand which heart failure episodes are attributed under CMS methodology, and maintain appropriate performance visibility without unnecessarily creating separate care models for every physician.

For many organizations, the more sustainable approach may be to strengthen core heart failure workflows across the practice while adding ASM-specific measurement and accountability where required.

ASM uses CMS attribution methodology to identify qualifying heart failure episodes for eligible Original Medicare beneficiaries.

Practices do not simply choose which patients to “enroll” in ASM. CMS constructs and attributes episodes according to model rules and the Heart Failure episode-based cost measure methodology.

This makes population visibility especially important: cardiology practices need to understand not only individual patient encounters, but also patterns of utilization, coordination, and cost across attributed heart failure episodes.

ASM can increase or decrease future Medicare Part B payments based on performance.

Participating specialists are evaluated under the model’s performance framework, and CMS applies future Part B payment adjustments based on results.

For cardiology practices, this means heart failure management can have implications beyond individual fee-for-service encounters. Cost, quality, coordination, improvement activities, and data exchange capabilities can influence overall model performance.

Yes. ASM creates downside financial exposure because future Medicare Part B payments may be negatively adjusted based on performance.

The exact financial impact depends on CMS methodology and the participant’s performance. Practices should model potential exposure using their actual Medicare mix, participating clinicians, heart failure population, and baseline performance rather than relying on generic national assumptions.

Yes. ASM can also create positive Medicare Part B payment adjustments for stronger performance.

The strategic goal should not be to optimize for a single measure in isolation. Practices need a coordinated approach to cost, quality, care delivery, required activities, and performance visibility.

Heart failure participants are evaluated across multiple performance categories, including cost, quality, improvement activities, and promoting interoperability.

For cardiology practices, this means ASM readiness is broader than reducing hospitalizations alone. Practices need to understand how clinical outcomes, episode cost, required care-improvement activities, and electronic information exchange fit together.

ASM includes required improvement activities focused on connecting specialty care with primary care and strengthening collaborative care.

Current CMS requirements include activities related to:

• Connecting patients to primary care

• Ensuring completion of health-related social needs screening

• Establishing communication and collaboration expectations with primary care

• Using collaborative care arrangements

For cardiology practices, these requirements make care coordination infrastructure a core ASM readiness issue rather than an optional enhancement.

Yes. Primary care coordination is built directly into ASM improvement activity requirements.

Participating specialists need processes that support communication, collaboration, and continuity between specialty and primary care.

Practices should assess whether these workflows are standardized, documented, measurable, and reliable across the heart failure population.

ASM improvement activity requirements include ensuring completion of health-related social needs screening.

Cardiology practices should determine how screening is completed, where results are documented, who owns follow-up, and how identified needs are incorporated into care coordination.

No. ASM does not automatically require a cardiology practice to create a separate heart failure service line.

Many practices can build on existing clinical and operational infrastructure. However, ASM does introduce specific performance and improvement requirements, so existing workflows may need to become more standardized, measurable, and coordinated.

The key question is not, “Do we already treat heart failure?” It is, “Can we consistently identify, coordinate, document, and improve the factors that drive ASM performance?”

No. ASM and Remote Patient Monitoring are different Medicare frameworks.

ASM is a mandatory specialty payment model for selected participants. RPM is a separately billable Medicare service for eligible patients who meet applicable requirements.

However, RPM may support broader heart failure management by helping care teams monitor clinically relevant physiologic trends between office visits.

No. ASM and Chronic Care Management are not the same program.

ASM is a mandatory performance-based payment model for selected specialists. CCM is a separately reimbursable Medicare care management service for eligible patients with multiple chronic conditions.

For cardiology practices, CCM infrastructure may support capabilities relevant to ASM, including longitudinal follow-up, medication coordination, care plan management, and communication across providers.

ASM does not inherently eliminate RPM or CCM billing for otherwise eligible patients.

Practices should continue to follow applicable Medicare requirements for patient eligibility, consent, device use, monitoring, treatment management, documentation, and billing. The strategic opportunity is to evaluate whether RPM infrastructure also strengthens heart failure care between visits and supports broader performance goals.

CCM remains a distinct Medicare service with separate eligibility, documentation, time, and billing requirements. Practices should evaluate CCM independently for compliance while also considering whether longitudinal care management supports broader ASM readiness.

RPM may support ASM readiness, but RPM participation alone does not guarantee better ASM performance.

For selected heart failure patients, remote monitoring may improve visibility into trends such as:

• Weight

• Blood pressure

• Heart rate

• Other clinically relevant physiologic data

The value depends on what happens after data is collected. Practices need defined review workflows, escalation protocols, timely intervention, patient engagement, and integration with the broader care plan.

Guideline-directed medical therapy, or GDMT, is an important component of high-quality heart failure care and should be evaluated as part of ASM readiness.

Cardiology practices should assess whether they can reliably:

• Identify potential therapy gaps

• Track medication changes

• Support follow-up after initiation or titration

• Document contraindications and barriers

• Coordinate with other treating clinicians

• Maintain visibility between office visits

The operational challenge is often not knowing what evidence-based care should look like. It is creating a reliable system for identifying and closing gaps across a complex patient population.

No. ASM does not require cardiology practices to use artificial intelligence.

However, technology may help practices identify risk, prioritize outreach, surface care gaps, support workflow management, and improve visibility across large patient populations.

AI should support clinical and operational decision-making, not replace clinician judgment.

No. ASM does not require cardiology practices to replace their EHR.

However, practices may need stronger capabilities for:

• Patient identification

• Episode and cohort visibility

• Care-gap tracking

• Cross-provider coordination

• Workflow management

• Performance monitoring

• Electronic information exchange

• Reporting

The practical question is whether the current technology environment can support the work ASM requires at scale.

Cardiology practices should use 2026 to confirm participation, establish baseline performance, map current heart failure workflows, and close high-priority operational gaps before ASM begins.

A practical readiness plan is available above.

An ASM readiness assessment evaluates whether a cardiology practice has the clinical, operational, financial, and technology infrastructure needed for the 2027 model.

A strong assessment should examine:

• Participant status

• Heart failure population

• Current workflows

• Cost performance

• Quality performance

• Required improvement activities

• Primary care coordination

• Social needs screening

• Medication optimization workflows

• RPM and CCM capabilities

• Data infrastructure

• Interoperability

• Financial exposure

• Governance and accountability

A practice may deliver excellent cardiology care and still lack consistent processes for:

• Tracking attributed populations

• Coordinating with primary care

• Identifying care gaps

• Managing high-risk patients between visits

• Documenting required activities

• Monitoring episode cost

• Understanding performance before payment adjustments occur

ASM turns these operational gaps into potential financial risk.

ISHI helps cardiology practices translate ASM requirements into practical heart failure care, operational, technology, and financial strategies.

ISHI can support:

• ASM readiness assessments

• Participant and population strategy

• Heart failure workflow design

• GDMT optimization workflows

• Primary care coordination strategy

• RPM and CCM alignment

• Care management design

• Technology strategy

• Performance measurement

• Financial modeling

• Implementation planning

The objective is not to add another disconnected program. It is to help cardiology organizations build a more coordinated, measurable, and scalable approach to heart failure care under value-based accountability.