CMS is building both the test
and the tools to pass it.
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.
The Accountability Side
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 Infrastructure Side
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.
These aren't reporting programs. They're operational infrastructure.
The Models
Ambulatory Specialty Model (ASM)
Mandatory for cardiologists (heart failure) and low back pain specialists starting January 2027. Payment adjustments of ±9% to ±12% of Part B revenue, scored against specialty and regional peers.
Learn about ASM preparationTEAM (Transforming Episode Accountability)
Launched January 2026, applying similar logic to hospitals. Mandatory participation in selected regions, episode-based accountability, financial risk tied to performance.
ACCESS (Advancing Chronic Care)
Launching July 2026. Creates a payment pathway for technology-enabled chronic disease management—hypertension, diabetes, obesity, and musculoskeletal pain. Providers get paid to manage patients proactively using remote monitoring and digital therapeutics.
LEAD (Long-term Enhanced ACO Design)
Replacing ACO REACH in 2027, runs for 10 years. Introduces CARA (CMS-Administered Risk Arrangements), which facilitate episode-based arrangements between ACOs and specialists.
Learn about our ACO infrastructureHow 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 Window Is Closing
ASM begins January 2027. 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.
Discuss your preparation strategy →