Downcoded

Who Got Drafted Into Medicare's Mandatory Specialty Model?

CMS posted the final CY2027 roster for the Ambulatory Specialty Model at 2:15 this afternoon. It names 5,533 clinicians in 232 CBSAs, and their CY2024 Medicare billing puts $118.6 million a year under a plus-or-minus 9 percent adjustment that nobody on the list volunteered for.


CMS updated one web page at 2:15 this afternoon, and 5,533 physicians found out they are in a mandatory payment model.

The final participant list for the Ambulatory Specialty Model is public. Five performance years, 2027 through 2031, with the money moving in payment years 2029 through 2033.

No opt-out, no application, no appeal of the geography that put you there.

"Who is actually on the list, and what is the swing worth?"

The Back Pain Cohort Is an Anesthesia Cohort

The file runs 5,556 rows over 5,533 distinct NPIs, spread across 232 core-based statistical areas and metropolitan divisions, 46 states, and 2,308 organizations. Texas alone carries 960 rows, California 586, Florida 481.

Two cohorts, scored separately against each other under 42 CFR 512.750(b). Heart failure is 2,214 clinicians and every one of them is a cardiologist.

Low back pain is 3,319, and that is where the surprise sits.

Anesthesia is the biggest bloc in it. Pain management, anesthesiology, and interventional pain management together are 1,493 of the low back pain cohort, or 45.0%, against 1,006 orthopedic surgeons and neurosurgeons combined.

Physical medicine and rehabilitation adds another 820.

So the low back pain cohort is mostly people who inject, and the heart failure cohort is where the dollars are (chart below).

One more thing to file. CMS built the collection-of-information burden in the CY2026 final rule around "approximately 7,622 ASM participants that will report data."

The final list came in at 5,533, about 27% short of the agency's own working number.

The rest of this brief is for subscribers.

The impact tables, the code-level detail, and the rest of the analysis sit past this line.

$50 a month, or $500 a year.