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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.

By VBCA·Reviewed by Kristy Reinert, MD·Published January 2, 2026·Updated September 23, 2026·3 min read

Between 2025 and mid-2026 the CMS Innovation Center ended some models, modified others, and announced several new ones. The announcements that matter most for specialists pair mandatory financial accountability with new payment pathways for the care that accountability rewards.

Mandatory Episode Risk Now Reaches Specialists

Specialists have mostly worked at the edge of value-based care. ACOs struggled to engage them, and bundled payment models focused on hospitals. MIPS does put up to 9% of Part B payments at risk, but clinicians choose most of their own quality measures and are scored against everyone who reports those measures.

The Ambulatory Specialty Model (ASM) takes those choices away for two groups beginning January 1, 2027: cardiologists who manage heart failure, and the pain management, anesthesiology, orthopedic surgery, neurosurgery, and PM&R physicians who treat low back pain. Participation is mandatory for clinicians in selected metro areas who meet the episode-volume threshold.

Larger adjustments. ±9% of Part B payments for 2027 and 2028 performance (paid in 2029 and 2030), rising to ±12% for 2031 performance.
A fixed measure set and a narrow peer group. Each cohort reports the same measures, and CMS compares participants only with others in their cohort (heart failure or low back pain) across all selected areas.
Built to save money. CMS redistributes 85% of each cohort's incentive pool and keeps the other 15%, so the model is not budget-neutral.

TEAM (Transforming Episode Accountability Model) applied the same logic to hospitals on January 1, 2026, with mandatory participation in selected regions and payment tied to episode cost and quality.

ACCESS and LEAD Pay for the Work ASM Scores

ACCESS (Advancing Chronic Care with Effective, Scalable Solutions) launched July 5, 2026, as a voluntary 10-year national model. It pays participating organizations for technology-supported chronic care such as remote monitoring, with full payment only when patients meet outcome targets. Its tracks cover cardio-kidney-metabolic conditions (hypertension, obesity, diabetes, chronic kidney disease, heart disease), chronic musculoskeletal pain, and depression and anxiety, which CMS says together affect more than two-thirds of people with Medicare.

LEAD (Long-term Enhanced ACO Design) replaces ACO REACH on January 1, 2027, and runs through 2036, the longest performance period CMS has tested for an ACO model. Its CMS-Administered Risk Arrangements (CARA) give LEAD ACOs under the Global Risk option the episode data, contracting templates, and payment calculations to put specialists into episode-based risk arrangements. CMS's tentative timeline makes 2028 the first CARA performance year.

How the Models Overlap

A patient whose blood pressure is controlled through ACCESS is less likely to become the expensive heart failure episode a cardiologist is scored on under ASM. An ACO that uses CARA to organize its specialists around low back pain episodes is building the same coordination ASM rewards. The episode math is shared as well: CARA episodes are built on the MIPS episode-based cost measure methodology, and ASM's cost category uses the heart failure and low back pain episode-based cost measures.

For a specialty practice, that argues for building chronic disease management, episode cost analytics, and referral coordination before scoring starts rather than after the first feedback report.

Where ASM Stands in September 2026

CMS published the final participant list for the 2027 performance year in September 2026: 5,556 participants, 2,215 in the heart failure cohort and 3,341 in the low back pain cohort, down from 6,637 on the February preliminary list. The CY2027 Physician Fee Schedule proposed rule adds ASM's year-one provisions, including subspecialty exclusions and a rural adjustment; the final rule is expected around November 1, 2026. See our proposed rule summary and the ASM overview.

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