CMS has released the Calendar Year (CY) 2027 Medicare Physician Fee Schedule Final Rule, with significant updates to the Quality Payment Program (QPP) and the Medicare Shared Savings Program. The rule is scheduled for publication in the Federal Register on Nov. 9, 2026, and takes effect Jan. 1, 2027.
PFS Final Rule: Changes for MIPS, MVPs and ACO reporting in 2026, 2027
Under ASM, you may be accountable for an MRI you didn't order
The proposed lumbar imaging measure attributes one scan to multiple clinicians. The 2024 data shows this machinery already at work.
The CY2027 Proposed Rule adds a claims-based measure of potentially unnecessary lumbar MRI use to the Ambulatory Specialty Model's low back pain cohort. Because it’s computed from administrative claims, it requires no reporting. That sounds like good news for busy practices.
Read the attribution design before agreeing. CMS proposes a 20-case minimum, a 365-day lookback, and attribution of each imaging event to multiple ASM participants whose care is sufficiently connected to it. One MRI can count against more than one clinician. Each carries individual two-sided payment risk on it. Neither is necessarily the one who ordered it.

We analyzed 37,825 spine, pain specialists. 105 have reported ASM’s proposed functional measure.
The low back pain cohort enters individual accountability in 2027 with almost no history on the measures it will carry.
We analyzed the most recent CMS Quality Payment Program data for the 37,825 clinicians in the 6 specialties that make up the Ambulatory Specialty Model's low back pain cohort: anesthesiology, interventional pain management, neurosurgery, orthopedic surgery, pain management, and physical medicine and rehabilitation.

We analyzed 11,424 cardiologists. 32 have reported ASM’s eCQM-only measure.
CMS has already given us the closest available preview of individual heart failure performance. The distribution isn't reassuring.
We analyzed the most recent CMS Quality Payment Program data for all 11,424 general cardiologists, the population the Ambulatory Specialty Model's heart failure cohort draws from. Only 32 of them reported Q377, Functional Status Assessments for Heart Failure, in 2024. Just 273 clinicians reported it across every specialty in American medicine.

ASM starts Jan. 1. Two in five specialists still don't know if it applies to them.
What the CY2027 Proposed Rule changes about the Ambulatory Specialty Model, and what it still leaves unresolved

On Jan. 1, 2027, selected specialists will begin participating in a mandatory CMS payment model with two-sided financial risk. Yet many organizations still don't know whether the model applies to them.
The Future of Value-Based Care
A new ten-year experiment called ACCESS is about to test exactly that question — and it could reshape how chronic illness is cared for in America.
Topics: VBC, Value-Based Care, Conference, APG, healthcare, ACCESS
For most of 2024 and 2025, the dominant frame for AI in healthcare was the copilot: AI suggested, a clinician acted. The framing was reassuring. It kept a human in every loop and let institutions defer the hard question of governance, because the AI never did anything a human hadn't already approved.
That framing is breaking down. At the APG Spring Meeting in San Diego this May, 4 organizations — an FQHC, a national VBC enablement company, a Southern California physician group, and UC San Diego Health — described deployments that have moved past copiloting into something more autonomous.
Topics: VBC, Value-Based Care, Conference, AI, APG, healthcare
The 80% problem: Why value-based care will be won in specialty
For roughly a decade, the operating assumption of value-based care has been that you transform outcomes and costs by transforming primary care:
• Attribute the patient to a PCP
• Hand the PCP a panel and a risk arrangement
• Give the care team a gap list
• Let the rest of the system carry on
That model has produced real wins. It’s also produced a generation of risk-bearing organizations that have squeezed most of what they can out of the levers a primary care physician controls and now find themselves staring at the part of the spend they don’t.
Topics: CMS, VBC, Value-Based Care, Conference, APG
For a decade, the question was whether to take risk. Now it's whether your measurement infrastructure can keep up.
About 1,300 medical group executives gathered at AMGA in Las Vegas last month. Most have already committed capital to value-based care. The strategic debate is over. A new one is starting.
Topics: CMS, VBC, Value-Based Care, MIPS Reporting, Conference, AMGA, AI
