Did you make the list? CMS targets cardiologists for new heart failure payment model

The U.S. Centers for Medicare and Medicaid Services (CMS) has released a list 2,600 cardiologists who will be required to participate in a new Ambulatory Specialty Model (ASM) payment model for heart failure starting on Jan. 1, 2027.

CMS said the new program aims to improve prevention and upstream management of high-cost chronic diseases with an initial push in heart failure and lower back pain. The new payment model is an attempt to reduce avoidable hospitalizations and unnecessary procedures. Heart failure is a major driver of Medicare expenses, and currently costs the U.S. health system about $179.5 billion annually.[1]

Participation in the ASM will be mandatory for certain specialists who commonly treat these conditions in Medicare patients in an outpatient setting. The ASM will begin on Jan. 1, 2027, and run for five performance years through Dec. 31, 2031.

ASM payment calculation details

Participants will have their Medicare Part B payments adjusted in the range of –9% to +9% in the first two payment years, 2028 and 2029, according to the American Society of Nuclear Cardiology (ASNC), which is closely monitoring the change and its potential impacts. The range of payment adjustments will increase in later years. The payment adjustment is at the individual level and applies to all of a physician's Part B claims.

ASMs are based on the Merit-based Incentive Payment System (MIPS) Value Pathways and measure provider performance in the areas of quality, care improvement, cost and interoperability. MIPS is one of the quality reporting programs under the Medicare physician payment system.

Physicians were assigned to the heart failure ASM if they met the key criteria of billing under the Medicare physician fee schedule; practicing in a CMS-targeted geographic areas; have the specialty designation of general cardiology; and historically treat at least 20 heart failure episodes per year.

CMS will use data from the calendar year two years prior to a given ASM performance year to evaluate these criteria. For example, CMS will use data from 2025 to determine final eligibility for the 2027 performance year.

Cardiology societies looking for clarity

ASNC is asking its members to see if they are on the ASM list and share any concerns. The society's goal is to better understand the broad impact this payment model might make on its members.

"We don't have a good grasp of how many of our members are specifically named in the list from CMS on the heart failure payment model and we’re trying to get members to reach out to us and let us know," ASNC Director of Regulatory Affairs Georgia Lawrence, JD, said in a statement to Cardiovascular Business.

The American College of Cardiology (ACC) also has questions about this policy. The group submitted formal comments to CMS outlining numerous concerns, including the focus on individual-level care and the lack of attention given to team-based care principles. ACC also identified certain operational and design flaws that could limit the program's effectiveness.

The ACC met with the Center for Medicare and Medicaid Innovation (CMMI) in February to discuss key elements of the ASM for heart failure. ACC said some of its members have raised concerns about their inclusion based on their Medicare Provider Enrollment, Chain and Ownership System (PECOS)-enrolled specialty type. The ACC has asked CMMI to reconfirm participant eligibility and validate the list. ACC Advocacy staff said they will continue to work with affected members to help provide clarity over the criteria for model participation.

Questions are also being raised over the heart failure episode-based cost measure currently used in MIPS, because this will account for 50% of a participant's ASM score. However, ACC said real-world data will not be publicly available until the release of the 2026 Quality Payment Program Experience Report using data from the 2024 performance year. The society emphasized that this makes clinician attribution difficult to determine.

ACC also asked the CMMI to share any actionable data with participants ahead of ASM implementation on Jan. 1.

CMMI encourages ASM participants to update their contact information to receive the latest news and updates directly from the agency.

ACC created a webpage on the heart failure ASM that include more information, a timeline and related advocacy efforts.

The new ASM mandatory participation list also includes more than 4,000 physicians who treat lower back pain, which is another high-cost driver for Medicare.