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.

Q377 is 1 of the 5 quality measures CMS finalized for mandatory heart failure accountability starting Jan. 1, 2027, a model that shifts participants to individual TIN/NPI accountability. ASM also has a group option only for practices of 15 or fewer clinician and carries two-sided payment risk on Medicare Part B.

Q377 is the only measure in either ASM cohort with no fallback: it's eCQM only, with no MIPS CQM option or registry abstraction path. If structured functional assessment data doesn’t flow from certified EHR technology, the measure can’t be reported.

That's a readiness problem sitting inside a mandatory model 4 months out.

The thesis of this analysis is simple: cardiology is entering individual accountability with essentially no individual reporting history on its own condition. Three pieces of evidence follow.

Evidence 1: The measure set, against what cardiology has actually done

A note on the points column: It describes only the clinicians who reported each measure, and small self-selected groups score high. Q377’s 9.00 reflects 32 practices that built the workflow early, not what the other 11,392 should expect. The one number reflecting the whole distribution is Q492’s 5.41, because nobody selects into a claims measure.

The therapy measures aren’t obscure. Q005 and Q008 have carried the same clinical logic for a decade. They go unreported for a structural reason, which is the next point.

Evidence 2: The structure that produced this is the structure ASM removes

In 2024, 6,627 of these cardiologists reported through a group, 2,833 through an APM entity, and 1,936 as individuals. 83% ride on submissions built by a multispecialty organization, scored on the measures that organization selected:

• Diabetes control on 59% of the cohort's records
• Blood pressure on 50%
• Tobacco screening on 40%
• Falls screening on 35%

Primary care measures, chosen by the group, applied to everyone in it, earning 8 or better.

That arrangement has been rational for a decade. A health system reports once, everyone receives the group’s score, and no cardiologist maintains an individual reporting operation.

ASM ends it. It calls for individual TIN/NPI assessment and a fixed condition-specific set, benchmarked only against other clinicians managing heart failure. The measure selection strategy that produced 10 years of comfortable scores is gone. For most ASM participants, so is the group reporting structure that executed it.

Evidence 3: The closest available preview of individual performance, and the distribution isn't reassuring

Q492, the risk-standardized unplanned cardiovascular admission measure, is computed automatically from claims. In 2024 it was computed for 5,730 general cardiologists — half the cohort.

• Mean: 5.41 points of 10
• Median: 5.0
• 31% at 3 points or fewer
• 12% at 10

The CY2027 Proposed Rule proposes scoring Q492 at the individual level. So for half the cohort, 1 of the 5 ASM quality measures already exists in preview form and is mediocre. There’s also no selection strategy to route around it because ASM has no measure selection.

Two caveats:

1. MIPS points are earned against national benchmarks and ASM benchmarks within the cohort, so 5.41 projects nobody's ASM score.
2. A claims outcome measure reflects attribution and risk adjustment, not just clinical decisions.

Neither changes the operational fact: the lone ASM measure with real performance history has an uncomfortable one.

What this means, and what to do before Sept. 14

The equation for a cardiology executive is this:

• Mandatory model
• Individual accountability
• Fixed measures
• One measure requiring infrastructure that 0.28% of the cohort has demonstrated
• Two-sided payment risk

That’s financial exposure with a 4-month fuse. Part of it, the Q377 infrastructure question, can’t be fixed quickly.

Comments on the CY2027 Proposed Rule close Sept. 14, 2026, at www.regulations.gov. The individual scoring of Q492 and the small-practice provision under which any group-level submission overrides every individual submission are both open for comment.

Independent of the final rule, we recommend three actions:

1. Treat Q377 as the critical path. Establish now whether standardized functional assessments can be captured and exported as structured data in your certified EHR. The answer will determine whether the measure is achievable.
2. Pull your cardiologists' Q492 history. Half of them have one, and it’s the closest thing to an ASM preview that exists.
3. Name 1 owner for submission governance. Cardiologists sit inside organizations with multiple reporting relationships. Under the Proposed Rule, one group-level file from any of them silently displaces every individual submission.

Where your cardiologists stand

National averages tell you where the cohort is vulnerable. They don't tell you whether your clinicians are.

That’s the analysis we’re offering organizations now. Send us your TIN and NPI roster, and within 2 business days we’ll identify:

• Which of your cardiologists fall within the heart failure cohort
• Who meets the episode-volume threshold
• Their 2024 reporting and scoring history across all 5 ASM measures, including the Q492 score CMS has already computed for half of general cardiology

There’s no cost or obligation.

Healthmonix is a CMS-approved Qualified Registry and Qualified Clinical Data Registry. We help specialty organizations and health systems determine ASM eligibility, evaluate historical cost and quality performance, model financial exposure, and prepare for reporting across ASM, MIPS, MVPs, and the Medicare Shared Savings Program. Contact us at contact@healthmonix.com.