We analyzed 37,825 spine, pain specialists. 105 have reported ASM’s proposed functional measure.

In 2024, 105 of them reported Q182, Functional Outcome Assessment, the measure the CY2027 Proposed Rule elevates to the center of low back pain quality assessment. That’s 0.28%. The measure it replaces was reported by 39.

Starting Jan. 1, 2027, ASM shifts these clinicians to individual TIN/NPI accountability, with a group option only for practices of 15 or fewer clinicians, on a fixed condition-specific measure set, benchmarked against only each other. Up to 9% of Medicare Part B payments will be at stake.

92% of them reported quality measures in 2024, so this isn’t a cohort that ignores reporting. It’s a cohort whose reporting looks nothing like what the model requires.

The thesis: ASM replaces the group reporting environment that has carried these specialists for a decade with individually accountable measures they have no history with. Three pieces of evidence follow.

Evidence 1: The functional measure family has no footprint, and the early adopters aren't succeeding

CMS isn’t replacing an unused measure with a used one. It’s selecting the least unused member of an unused family.

Every functional status measure available to this cohort — Q182, the retiring Q220, and the 2 FOTO measures — sits between 39-105 reporters across 37,825 clinicians. The 105 clinicians who reported Q182 averaged 6.08 points of 10, with none reaching 10 and 15% at 3 or fewer. Even the practices that chose this measure haven’t mastered it.

Q182 isn’t a checkbox. It requires a standardized functional assessment and a documented care plan for identified deficits. That means an instrument selection, an EHR template, and a clinical workflow. The final rule arrives in November. Practices that wait for it will build all 3 in under 2 months.

The rest of the finalized set is thin in the same way:

• Q134 depression screening has real history at 22.9%, mostly inherited through group submissions.
• Q238 high-risk medications sits at 5.7% with the weakest actively reported score in the set at 6.31.
• Q128 BMI screening sits at 1.2%.

Evidence 2: The scaffolding being removed is the whole story of this cohort's reporting

In 2024, 88% of the 37,825 reported through a group or APM entity. Only 4,541 reported as individuals.

Those group submissions were built by multispecialty organizations. What those submissions contain — diabetes control, tobacco screening, falls screening, and blood pressure — isn’t spine care. Those submissions contain primary care measures the organization selected because it performs well on them, earning 7.5-8.6 mean points and applied to every clinician in the group.

Under ASM's individual accountability, the submission that has carried these specialists through MIPS for a decade can't carry them. The comfortable scores it produced say nothing about what individual, condition-specific, cohort-benchmarked scoring will look like.

Evidence 3: A second exposure that has nothing to do with reporting

The proposed lumbar MRI measure is computed from claims, with a 365-day lookback and attribution to multiple ASM participants whose care is sufficiently connected to the imaging event. One MRI can count against multiple physicians, each carrying individual two-sided risk, neither necessarily the one who ordered it.

Our 2024 analysis shows this kind of attribution already reaching the cohort: of 11,442 low-back pain specialty clinicians, 30%, carried a heart failure admission measure on their 2024 records through the multispecialty TINs they bill under.

Claims attribution doesn’t stop at specialty boundaries. Under ASM it arrives with individual payment risk attached.

We’ll examine the attribution design, and what to do about it, in a separate analysis.

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

Comments on the CY2027 Proposed Rule close Sept. 14, 2026, at www.regulations.gov. The attribution design of the imaging measure, the timing of a workflow-changing measure substitution 4 months before a mandatory year, and the small-practice provision under which any group-level submission silently overrides every individual submission are all open for comment.

Independent of the final rule, your practice can take 4 actions:

1. Start the Q182 workflow now. Instrument, template, and staff training don’t fit in the post-final-rule window.
2. Stand up reporting for Q238 and Q128, which under 6% and 2% of this cohort has ever submitted.
3. Audit 12 months of lumbar MRI ordering across your roster to see your exposure under the proposed attribution logic.
4. Name 1 submission owner across your EHR, billing, and registry relationships, because 1 stray group-level file overrides everything.

Where your clinicians 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. Within 2 business days we’ll identify:

• Which of your clinicians fall within the low back pain cohort
• Who meets the episode-volume threshold
• Their 2024 reporting and scoring history on the measures ASM will assign, including the claims measures already computed for them

There’s no cost or obligation.