As CMS continues to evolve value-based care, the Ambulatory Specialty Model (ASM) in the 2026 Physician Fee Schedule (PFS) Proposed Rule represents a landmark opportunity for specialists who have historically been excluded from broader accountable care models like MSSP and ACO REACH. 

What is the Ambulatory Specialty Model? 

The ASM is a proposed voluntary payment model that aims to integrate specialists into value-based care by focusing on high-volume, high-cost specialty care in outpatient settings. It’s built around episode-based payment structures. These tie financial and performance accountability to defined episodes of care such as joint replacements, chemotherapy regimens, or cardiac interventions. 

Participating providers will be evaluated based on cost efficiency, quality outcomes, and patient experience metrics. The model aims to align with the types of care specialists deliver and incentivize them to improve coordination, reduce unnecessary spending, and focus on outcomes. 

Key benefits 

1. Inclusion of specialists
   The ASM offers a long-overdue opportunity for specialists to participate in value-based care. Unlike primary care-led ACOs, the ASM model puts specialists at the center of performance measurement and financial risk.
2. Focus on episode-based efficiency
   ASM defines episodes around high-impact conditions and procedures. This encourages efficient care pathways, reduced readmissions, and eliminating duplicative services.
3. Performance-based incentives
   Specialists can earn bonuses based on performance in key metrics: patient outcomes, experience of care, and episode cost benchmarks.
4. Tailored reporting and alignment with MVPs
   ASM is expected to align with MIPS Value Pathways (MVPs). This will offer specialty-relevant reporting and minimize administrative burden by integrating into existing CMS reporting structures.
5. Empowering innovation in specialist-led care
   By giving specialists financial accountability, ASM may accelerate innovation in post-acute planning, remote monitoring, and procedural standardization.

Concerns and open questions 

1. Attribution and episode design
   How will CMS define episodes and attribute outcomes to specialists? Without clear guardrails, providers could be held accountable for factors outside their control.
2. Data and infrastructure gaps
   Small or independent specialty practices may lack the resources or tools to track episode-level data or participate in advanced payment models.
3. Risk adjustment and benchmarking
   Robust risk adjustment is essential to avoid penalizing providers who serve more complex patients. CMS must ensure fair benchmarking for diverse practice types.
4. Model overlap and administrative complexity
   ASM could create confusion and duplication with existing programs like BPCI Advanced, Oncology Care Model (OCM), or ACOs. CMS must clarify how participation in ASM would affect or interact with these models.
5. Voluntary nature and adverse selection
   Voluntary participation may lead to selection bias, where only high-performing or low-risk providers opt in. That could distort results.

What’s next? 

ASM remains in the proposed stage, with CMS soliciting public feedback. Stakeholders — including medical societies, technology vendors, and health systems — have a window to influence how episodes are defined, performance is measured, and burdens are managed. 

CMS is expected to release more technical specifications in the Final Rule later this year. Before then, organizations should start evaluating: 

• What specialties or episodes they may qualify for
• How ASM aligns with their MIPS/MVP strategy
• What reporting or analytics infrastructure they’ll need

Final thoughts 

The Ambulatory Specialty Model is CMS’ most targeted effort to integrate specialists into Medicare’s value-based ecosystem. If implemented thoughtfully, it could drive measurable improvements in quality and cost while giving specialists more control over their financial future. 

Now is the time for specialists and health systems to consider this model, talk with Healthmonix about the impact, engage with CMS, and ensure this model supports real-world care delivery. 

Stay with Healthmonix for expert insights, guidance, and solutions to help you navigate the new frontier of value-based specialty care in 2026 and beyond.