ASM Preparation: What You Can Do Now

The data already exists. The question is whether you're using it.

Introduction

You have approximately twelve months before ASM performance measurement begins. That's not enough time to overhaul your practice—but it's enough time to understand where you stand and address the gaps that matter most.

This guide walks through what you can do now with data and infrastructure that already exists. Some of this work requires investment. Some of it just requires attention. All of it is easier to do before January 2027 than after.

Whether you're in a mandatory area or not, the capabilities ASM rewards are the same capabilities that drive sustainable practice performance. The preparation isn't wasted either way.

Assess Your Participation Status

Why This Matters

Not every specialist in a mandatory area will face payment adjustments. You need to meet both the geographic and volume criteria. Understanding your likely status determines how urgently you need to prepare.

What to Do

Step 1: Confirm your geographic status. Check whether your practice location falls within one of the 235 mandatory CBSAs. If you practice in multiple locations, assess each—ASM participation is determined by where services are rendered, not where your billing address sits.

Check if your area is mandatory →

Step 2: Estimate your episode volume. For the 2027 performance year, CMS will use 2025 episode data to determine eligibility. You need 20+ attributed episodes in the relevant condition.

For cardiologists (heart failure):

• Pull your Medicare claims with heart failure diagnosis codes
• An episode requires two Part B claims within 180 days from the same patient
• You must bill ≥30% of Part B services within the episode to have it attributed to you

For low back pain specialists:

• Pull claims with ICD-10 low back pain diagnoses
• An episode requires a confirming code within 60 days
• Same 30% attribution threshold applies

If you're unsure how to pull this data, your billing system or registry should be able to help. Our platform includes episode volume estimation for clients who need it.

Step 3: Identify your comparison pool. ASM benchmarks you against peers treating the same condition nationally. Heart failure participants are compared against other cardiologists in mandatory areas. Low back pain specialists—orthopedic surgeons, neurosurgeons, pain management, anesthesiologists, and PM&R—are all scored in the same pool.

You're not competing against your local market. You're competing against specialists nationwide treating similar patients.

Understand Your Cost Position

Why This Matters

Cost accounts for 50% of your ASM score. If you don't know your current episode costs relative to peers, you're flying blind. The same patients driving your MIPS episode-based cost measures will drive your ASM performance.

What to Do

Step 1: Access your MIPS cost feedback. If you've participated in MIPS, CMS provides annual feedback reports showing your performance on episode-based cost measures. These reports include your average episode cost, the national benchmark, and your percentile ranking. This data is typically 12-18 months old by the time you receive it, but it's the best baseline available.

Step 2: Identify your high-cost episodes. Cost variation usually concentrates in specific patients or service categories. Look for patterns:

For heart failure episodes:

• Hospitalizations for acute decompensation are the primary cost driver—a single inpatient stay can push an episode into the top cost decile
• Repeat echocardiograms without clinical indication add imaging costs that benchmarks expose
• Post-acute care (SNF, home health) following hospitalization often doubles episode cost

For low back pain episodes:

• Advanced imaging early in the episode (MRI within 30 days of initial presentation) correlates with higher total episode costs
• Injections and procedures vary widely in their impact—multiple procedures in quick succession raise flags
• Surgical intervention versus conservative management creates the largest cost divergence

The goal isn't to deny care. It's to understand where costs are generated so you can evaluate whether alternative approaches might achieve similar outcomes.

Step 3: Compare your utilization patterns. Within your cost feedback, look at service category breakdowns: How does your imaging utilization compare to benchmark? What percentage of your episodes include hospitalization? How much post-acute spending appears in your episodes?

The platform loads CMS cost data and surfaces episode-level costs, patient-level drivers, and peer comparisons—standard functionality.

Prepare for Quality Measure Reporting

Why This Matters

Quality also accounts for 50% of your ASM score. Unlike traditional MIPS where you select measures, ASM requires reporting on all measures in your cohort. The 75% data completeness threshold means gaps in reporting become zeros in scoring.

What to Do

Step 1: Review your current performance on ASM measures. Most ASM measures already exist in MIPS. If you've been reporting them, you have baseline data:

Heart failure measures:

Low back pain measures:

If you haven't been reporting these measures, start now. A year of baseline data helps you understand where you stand before it counts.

Step 2: Address the patient-reported measures. Both cohorts include patient-reported functional status measures. These require standardized assessment tools, baseline assessment at episode start, and follow-up assessment to measure change.

This is where most practices struggle. Collecting patient-reported outcomes requires patient engagement, staff training, and EHR integration. It's not something you implement in December 2026.

Step 3: Audit your data completeness. The 75% rule means you need to report on at least 75% of eligible cases for each measure. Audit your current reporting: What percentage of eligible patients are you capturing? Where are patients falling through the cracks—scheduling, documentation, data extraction? If you're below 75% on any measure that will be required for ASM, you have a gap that needs addressing before 2027.

Build Primary Care Relationships

Why This Matters

ASM includes Improvement Activities that carry a potential −20 point penalty. These aren't generic quality improvement activities—they specifically require primary care coordination and collaborative care arrangements. If you've operated as a referral-based practice without structured PCP relationships, this is the hardest requirement to meet quickly.

What to Do

Step 1: Understand what CMS requires. The Improvement Activities category has two components:

For more detail on scoring implications, see The Ambulatory Specialty Model Explained.

Step 2: Identify your top referral sources. Pull your referral data to identify which primary care practices send you the most patients. Focus your outreach on the 3-5 practices that account for the majority of your shared patients.

Step 3: Initiate formal arrangement discussions. A collaborative care arrangement doesn't require complex contracting—it can be a documented memorandum of understanding between practices. But it does require explicit agreement on the required elements.

Start these conversations now. Formalizing relationships takes longer than most practices expect.

Test Your Reporting Infrastructure

Why This Matters

ASM uses the same reporting mechanisms as MIPS—eCQM, MIPS CQM, or claims-based submission depending on the measure. But the stakes are higher. A reporting infrastructure that "mostly works" isn't good enough when 75% completeness is required and 12% of revenue is at risk.

What to Do

Step 1: Audit your current MIPS reporting. Look at your most recent MIPS submission: What was your data completeness rate for each measure? Were there measures where you fell below 75%? What caused the gaps—patient exclusions, documentation issues, extraction errors?

Step 2: Identify single points of failure. Many practices have reporting infrastructure that depends on one person who knows how to run the extraction, manual chart review to supplement automated extraction, or end-of-year scramble to close documentation gaps. These work for MIPS, where the stakes are modest. They're risky for ASM. Identify dependencies and build redundancy.

Step 3: Verify your Promoting Interoperability compliance. ASM includes a −10 point penalty for failing to meet Promoting Interoperability requirements. These mirror MIPS but are reported at the TIN level. Confirm you meet the requirements:

• Using 2015 Edition or later Certified EHR Technology (CEHRT)
• Completing Security Risk Analysis annually
• Meeting e-Prescribing thresholds
• Achieving Health Information Exchange requirements (sending/receiving or bidirectional)
• Providing patients electronic access to their health information
• Reporting to required public health registries

If your practice has historically relied on the Promoting Interoperability hardship exception in MIPS, you won't have that option in ASM.

Step 4: Run a test submission. Before the stakes are real, run your reporting workflow as if it were: Extract data as you would for MIPS submission, validate completeness and accuracy, identify issues and fix them. A test run in Q3 2026 gives you time to address problems before 2027 performance year begins.

Timeline-Based Action Plan

Here's a quarter-by-quarter breakdown of what to accomplish before ASM begins:

Q1 2026 (Now) — Assessment:

• Confirm geographic status
• Estimate episode volume and participation likelihood
• Review current quality measure performance
• Access MIPS cost feedback data
• Identify top PCP referral sources and begin outreach

Q2 2026 — Infrastructure Development:

• Implement patient-reported outcome collection workflows (KCCQ-12 or ODI/PROMIS-29)
• Set up real-time reporting completeness monitoring
• Establish cost visibility mechanisms
• Draft collaborative care arrangements with PCPs

Q3 2026 — Testing:

• Run test data extraction and submission
• Audit completeness rates and address gaps
• Verify cost data is flowing and interpretable
• Confirm Promoting Interoperability compliance
• Staff education on ASM requirements and workflow training

Q4 2026 — Final Preparation:

• Finalize all arrangements and workflows
• Confirm reporting infrastructure is production-ready
• Review CMS's final participant notification (expected mid-2026)
• Brief clinical staff on January 2027 start

If You're Not in a Mandatory Area

Why Prepare Anyway?

Even if your practice location isn't in the 235 mandatory CBSAs, the capabilities ASM rewards are worth building:

Adjusted Priorities

If you're not facing mandatory participation, prioritize differently:

• Cost visibility: Still valuable—helps you understand practice efficiency
• Quality measure reporting: Continue as you would for MIPS
• Primary care relationships: Lower urgency, but still worth building
• Reporting infrastructure: Maintain current standards

Treat ASM preparation as capability-building rather than compliance scramble.

Closing

Twelve months isn't much time for wholesale practice transformation. But it's enough time to understand where you currently stand, address the highest-risk gaps, build relationships that take time to develop, and test infrastructure before the stakes are real.

The practices that struggle with ASM won't be the ones with the worst clinical performance. They'll be the ones who waited until Q4 2026 to start preparing, discovered infrastructure gaps, and ran out of time to fix them.

If you want to assess your readiness or see how your current data maps to ASM methodology, we can help.

Talk to us about ASM preparation →

Related Resources

• Policy Analysis: Full breakdown of ASM → /insights/ambulatory-specialty-model-explained
• Geographic Tool: Check if your area is mandatory → /asm#eligibility-tool

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