Most of what ASM will score in 2027 is already visible in the claims and MIPS data you have today.

The time left before January 1 won't cover an overhaul of your practice, but it is enough to learn where you stand, close the gaps that cost the most points, and start the primary care relationships that take longest to formalize. The same capabilities lift MIPS performance, so the work holds its value even if you never face an ASM adjustment.

What this guide covers:

01|Confirming your participation status →
02|Understanding your current cost position →
03|Preparing for quality measure reporting →
04|Building the primary care relationships ASM requires →
05|Testing your reporting infrastructure →
06|What to finish before January 1, and after →
07|If you're not in a mandatory area →
08|The readiness checklist →

Assess Your Participation Status

Confirm your status on the final list. CMS posted the final 2027 list to data.cms.gov in September 2026. Its recheck against 2025 claims could only remove clinicians, so if you weren't on the February preliminary list, you are not in ASM for 2027. Check every TIN/NPI combination; a clinician who qualifies under two TINs is two participants.

Check if your area is mandatory →

Know how CMS counts for 2028 and later. Eligibility requires 20 or more attributed episodes two calendar years before the performance year, so 2026 claims decide 2028.

For cardiologists (heart failure):

Pull your Medicare claims with heart failure diagnosis codes
An episode requires two Part B claims within 180 days for 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

Your billing system or registry can usually pull this; our platform also estimates episode volume for clients. Know your comparison pool, too: ASM benchmarks you against every participant in your cohort across all 235 mandatory areas, not your local market. All five low back pain specialties share one pool.

Understand Your Cost Position

Cost is half the ASM score, and the patients driving your MIPS episode-based cost measures will drive it in ASM. Start with your annual MIPS feedback report: average episode cost, national benchmark, and percentile. The data is 12 to 18 months old when it arrives, but it is the best baseline available. Cost variation usually concentrates in specific patients or service categories:

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 aim is to see where costs arise and whether other approaches reach similar outcomes; nothing here requires denying care. Our platform loads CMS cost data and shows episode-level costs, patient-level drivers, and peer comparisons as standard functionality.

Prepare for Quality Measure Reporting

Quality is the other half. ASM requires every measure in your cohort, and any measure below 75% data completeness scores zero. Most ASM measures already exist in MIPS, so if you have been reporting them, you have a baseline:

Heart failure measures:

Measure	Description
Q008	Beta-blocker therapy for LVSD
Q005	ACE/ARB/ARNI therapy for LVSD
Q236	Controlling high blood pressure
Q377	Functional status assessments (eCQM only)
Q492	Risk-standardized CV admission rates (claims-based; CMS calculates)

Low back pain measures:

Measure	Description
Q238	High-risk medications in older adults
Q134	Depression screening and follow-up
Q128	BMI screening and follow-up
Q220	Functional status change for LBP (proposed for replacement by Q182)

If you haven't been reporting these, start now. Patient-reported functional status is where most practices struggle: it needs a standardized instrument, a baseline, and follow-up, which means patient engagement, staff training, and EHR integration.

Heart failure (Q377): the Kansas City Cardiomyopathy Questionnaire (KCCQ-12), 12 items and about 4 minutes, covering physical limitation, symptoms, quality of life, and social limitation. CMS accepts it for Q377, which is eCQM-only, so the score has to land in a structured EHR field.
Low back pain (Q220): the Oswestry Disability Index (ODI), more common in spine practice, or the PROMIS-29 physical function domain, which covers broader quality of life. You need baseline and follow-up scores to show change. CMS proposed in July 2026 to replace Q220 with Functional Outcome Assessment (Q182), which names the Modified ODI and PROMIS as appropriate tools, so the same workflow serves either measure.

Audit your data completeness. For each measure, find where eligible patients fall out (scheduling, documentation, or extraction). Any required measure below 75% is a gap to close before January.

Build Primary Care Relationships

ASM's two required Improvement Activities cost 10 points each if missed, and both concern primary care. For a referral-based practice, this is the hardest requirement to meet quickly.

Activity 1: confirm each beneficiary has a primary care provider (help them find one if not), update the PCP after each visit, and check for an annual health-related social needs (HRSN) screening in primary care, prompting the PCP or screening the patient yourself if there wasn't one.
Activity 2: sign at least one collaborative care arrangement with a primary care practice that shares ASM beneficiaries, covering at least three of five elements: data sharing, co-management, transitions in care, closed-loop communication, and care coordination integration.

Each activity must run for at least 90 consecutive days within the performance year (scoring detail is in The Ambulatory Specialty Model Explained). Use your referral data to find the three to five primary care practices that account for most of your shared patients. The arrangement needs no complex contracting, but it must be written, signed, and dated, keep the PCP's participation voluntary, and leave each side's clinical decisions its own.

Example arrangement: A cardiology practice and a three-physician primary care group agree in writing to (1) share patient information bidirectionally through secure messaging when clinical events occur, (2) define which patients qualify for co-management and how decisions will be coordinated, and (3) run a closed-loop referral process in which the specialist sends a summary within 48 hours and the PCP acknowledges receipt. Signed and dated by both practice leaders, that covers three of the five elements; the agreement also has to meet the other conditions in 42 CFR 512.771.

Formalizing these relationships takes longer than most practices expect, so they sit at the front of the timeline below.

Test Your Reporting Infrastructure

ASM uses MIPS submission mechanics (eCQM, MIPS CQM, or claims) and the same QPP portal, but it requires 75% completeness on every measure and puts 9% of all Part B payments at risk in the first year, 12% by 2031. Check your latest MIPS submission for measures under 75% and the cause of each gap. Then look for single points of failure: one person who knows the extraction, manual chart review behind automated extraction, a year-end scramble on documentation. Practices get by with these in MIPS; under ASM they are a real exposure.

Promoting Interoperability (up to −10 points, reported at the TIN level) requires a CEHRT ID, the annual Security Risk Analysis and SAFER Guides self-assessment, e-Prescribing, health information exchange, patient electronic access, and public health registry reporting. ASM's regulations have no equivalent of the MIPS hardship exception for this category; relief is limited to extreme and uncontrollable circumstances.

Your 2026 MIPS submission is the natural test run: CMS says clinicians eligible for MIPS in 2026 must still report it, even if they are on the ASM list. Run it as if it counted and fix what breaks.

Timeline-Based Action Plan

Before January 1, 2027

Work through the checklist below, starting with the collaborative care arrangement and functional status workflow because they take longest. Read the CY2027 final rule when it publishes (expected around November 1) for measure and scoring changes, and brief clinical staff before the year opens.

First 90 days of 2027

Confirm both improvement activities are running, which starts their 90-day clock
Monitor data completeness monthly for each measure
Set a quarterly review of quality and cost trends for the rest of the year

By March 31, 2028

Submit 2027 quality, Improvement Activities, and Promoting Interoperability data; CMS calculates cost from claims

If You're Not in a Mandatory Area

Outside the 235 mandatory areas, the same capabilities are worth building on a slower schedule. Episode-based cost measures carry more weight in MIPS, MVPs emphasize condition-specific reporting, and ASM may expand if it meets CMS's savings targets. Cost visibility is still worth having, quality reporting continues as for MIPS, and primary care relationships can wait a little but are worth starting.

ASM Readiness Checklist

□ Confirmed each clinician's status on the final 2027 CMS list

□ Estimated 2026 episode volume, which decides 2028 eligibility

□ Know which cohort pool you're benchmarked against

□ Pulled MIPS cost feedback and identified the highest-cost episodes

□ Have ongoing cost visibility, not just annual reports

□ Reviewed performance on every ASM measure in your cohort

□ Functional status instruments in use at baseline and follow-up (KCCQ-12 for HF; ODI or PROMIS-29 for LBP)

□ Data completeness is at or above 75% for each measure

□ Identified the primary care practices with the most shared patients

□ Signed at least one collaborative care arrangement

□ Workflows track PCP assignment, post-visit updates, and HRSN screening status

□ Verified all Promoting Interoperability requirements

□ Removed single points of failure in reporting and ran a test extraction

Any box still unchecked is a gap worth closing first. If you'd rather have us run the assessment, send us your MIPS cost feedback report and your practice locations.

Have us score your checklist →