CMS Is Building Both the Test and the Tools to Pass It
What the Innovation Center's 2025–2026 model announcements mean for specialists—and why the preparation window matters.
The Innovation Center had a busy 2025. Between model terminations, modifications, and a wave of new announcements, it can be hard to see the forest for the trees. But there's a pattern emerging that specialists should pay attention to—especially those in cardiology, pain management, anesthesiology, orthopedics, PM&R, and neurosurgery.
CMS isn't just raising the stakes. It's giving providers the infrastructure to succeed within them.
That pairing—accountability plus operational pathways—is the thread connecting the most consequential model announcements of the past year. Understanding how these pieces fit together matters more than any single model's details.
The Accountability Side: Mandatory Risk Is Here
For years, specialists have largely operated outside the value-based care ecosystem. ACOs struggled to engage them. Bundled payment models focused on hospitals. MIPS, for all its reporting burden, never introduced real downside risk.
That's changing.
The Ambulatory Specialty Model (ASM) makes participation mandatory for certain cardiologists (heart failure cohort) and clinicians who treat low back pain (pain management, anesthesiology, orthopedics, neurosurgery, PM&R) beginning January 2027. It's been called "MIPS on steroids"—and that's accurate.
Meanwhile, TEAM (Transforming Episode Accountability Model) launched January 2026, applying similar logic to hospitals. Mandatory participation in selected regions, episode-based accountability, financial risk tied to performance. The direction is clear: specialty-specific, episode-based, real financial accountability is no longer optional for a growing share of the provider landscape.
The Infrastructure Side: Tools to Succeed
Here's what makes the current moment different from previous CMS pushes toward value: the Innovation Center isn't just mandating accountability. It's creating pathways that help providers deliver on it.
ACCESS (Advancing Chronic Care with Effective, Scalable Solutions) creates a payment pathway for technology-enabled chronic disease management. Launching July 2026, the model focuses on hypertension, diabetes, obesity, and musculoskeletal pain—conditions affecting more than two-thirds of Medicare beneficiaries.
Providers participating in ACCESS get paid to manage patients proactively, using remote monitoring, digital therapeutics, and continuous engagement beyond the traditional office visit. This isn't a reporting program. It's operational infrastructure for managing the upstream conditions that drive costly episodes downstream.
LEAD (Long-term Enhanced ACO Design) takes a different angle on the same problem. Replacing ACO REACH in 2027, LEAD runs for 10 years—the longest ACO model CMS has ever tested—and introduces CMS-Administered Risk Arrangements (CARA), which facilitate episode-based arrangements between ACOs and specialists.
How the Pieces Connect
The relationship between these models isn't accidental.
A patient with well-controlled blood pressure through ACCESS is less likely to become a complicated heart failure episode that costs a cardiologist under ASM. An ACO using LEAD's CARA framework to align specialists around low back pain episodes is building exactly the care coordination infrastructure that ASM will reward.
CMS is building both the test and the tools to pass it.
The organizations that recognize this—and invest in chronic disease management pathways, episode-level analytics, and specialist coordination now—will be better positioned when mandatory accountability arrives. Those that wait may find themselves scored on capabilities they haven't yet developed.
The Window Is Closing
ASM begins January 2027. That's twelve months away.
CMS will release preliminary participant lists in early 2026 and finalize them mid-year. Specialists in selected regions won't have the option to sit this out.
The question isn't whether value-based accountability is coming for specialists. It's whether you're using the time you have to understand your cost position, build coordination infrastructure, and develop the episode-level analytics that these models require.
The organizations treating this window as a learning opportunity—not just business as usual—will be better prepared when "voluntary" becomes "mandatory."