Lexology July 31, 2025
On July 14, 2025, the Centers for Medicare & Medicaid Services (“CMS”) announced its CY 2026 Physician Fee Schedule (“PFS”) Notice of Proposed Rulemaking (“Proposed Rule”). The Proposed Rule includes information on a new Center for Medicare & Medicaid Innovation (“CMMI”) mandatory payment model called the Ambulatory Specialty Model (“ASM”). If finalized, the new mandatory model would begin on January 1, 2027, and run through December 31, 2031.
The ASM falls within CMMI’s larger framework of activities focusing on high-volume, high-cost chronic conditions and direct engagement of specialists in value-based care. The model focuses on improving care for two high-cost, high-utilization chronic conditions in the Medicare population: heart failure and low back pain. The stated goal of ASM is to...







