Expanding value-based care to specialists: What the 2026 Ambulatory Specialty Model means for the future of Medicare
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What is the Ambulatory Specialty Model?
Key benefits
Inclusion of specialists The ASM offers a long-overdue opportunity for specialists to participate in value-based care. Unlike primary care-led ACOs, the ASM model puts specialists at the center of performance measurement and financial risk.
Focus on episode-based efficiency ASM defines episodes around high-impact conditions and procedures. This encourages efficient care pathways, reduced readmissions, and eliminating duplicative services.
Performance-based incentives Specialists can earn bonuses based on performance in key metrics: patient outcomes, experience of care, and episode cost benchmarks.
Tailored reporting and alignment with MVPs ASM is expected to align with MIPS Value Pathways (MVPs). This will offer specialty-relevant reporting and minimize administrative burden by integrating into existing CMS reporting structures.
Empowering innovation in specialist-led care By giving specialists financial accountability, ASM may accelerate innovation in post-acute planning, remote monitoring, and procedural standardization.
Concerns and open questions
Attribution and episode design How will CMS define episodes and attribute outcomes to specialists? Without clear guardrails, providers could be held accountable for factors outside their control.
Data and infrastructure gaps Small or independent specialty practices may lack the resources or tools to track episode-level data or participate in advanced payment models.
Risk adjustment and benchmarking Robust risk adjustment is essential to avoid penalizing providers who serve more complex patients. CMS must ensure fair benchmarking for diverse practice types.
Model overlap and administrative complexity ASM could create confusion and duplication with existing programs like BPCI Advanced, Oncology Care Model (OCM), or ACOs. CMS must clarify how participation in ASM would affect or interact with these models.
Voluntary nature and adverse selection Voluntary participation may lead to selection bias, where only high-performing or low-risk providers opt in. That could distort results.
What’s next?
What specialties or episodes they may qualify for
How ASM aligns with their MIPS/MVP strategy
What reporting or analytics infrastructure they’ll need
