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Are you already in a mandatory risk model?

The Ambulatory Specialty Model is mandatory and has no opt-out. Performance year one begins 1 January 2027. CMS has already published the preliminary list of clinicians who must participate. Check your NPI against it.

Your NPI is public information and is sent only to CMS’s open data API. Nothing is stored, logged to an account, or shown to anyone else.

What the model actually does

ASM runs five performance years, 1 January 2027 through 31 December 2031, and it scores an individual clinician — identified by TIN and NPI — rather than a hospital. The low-back-pain cohort names orthopaedic surgery alongside neurosurgery, anaesthesiology, pain management, interventional pain management and physical medicine and rehabilitation. Eligibility is historic: at least 20 attributed episodes from the relevant episode-based cost measure in the calendar year two years prior. There is no application, and there is no opt-out.

CMS’s preliminary file lists 4,027 low-back-pain participants and 2,610 heart-failure participants — 6,637 clinicians in total, read 10 September 2026.

The part nobody has reconciled

ASM proposes to score participants on longitudinal patient-reported outcomes. Remote therapeutic monitoring is how that data gets collected and paid for — and the two rules do not currently meet.

Monitoring during a global period “may be billed by practitioners that are not receiving the global service payment”. A surgeon who operates is receiving it. And only one practitioner may bill monitoring for a patient in a 30-day period, so the slot may be held by a therapist instead. The result: a clinician can be scored on outcome data across a window in which they may be barred from billing the monitoring that produces it.

We filed that question with CMS on this rule. The full argument, with the arithmetic →

What this tool will not do

  • It will not tell you that you are exempt. This file is preliminary. CMS publishes the final CY2027 list later in 2026 and may add participants from CY2028. An absent NPI means absent from a draft, nothing more.
  • It will not let you browse or search other clinicians. Exact NPI only — no name search, no list, no export. It answers “am I in this?”, never “who is in this?”
  • It will not rank anybody, score anybody, or publish an outcome about anybody.
  • It is not billing, legal or tax advice, and it is not a substitute for CMS correspondence. If the answer matters to you, confirm it with CMS directly.

Data: CMS Ambulatory Specialty Model Participants public use file, queried live from data.cms.gov — free, keyless, and updated by CMS annually. Model detail from the ASM model page and participant FAQ; monitoring rules from telehealth.hhs.gov. All read 10 September 2026. Questions: blaine@solvinghealth.com